The Federal Trade Commission’s recent announcement that it entered into a record settlement with “the world’s largest debt collection operation” demonstrates that it intends to continue its vigorous enforcement of the Fair...more
Jeff Sovern has written an interesting blog post about the CFPB’s recent Bulletin 2013-07 that warns creditors and servicers who are not covered by the FDCPA that their collection practices are subject to the CFPB’s authority...more
The Consumer Financial Protection Bureau made clear that debt collection continues to be a major focus by issuing two new bulletins and five action letters for consumers to use when responding to debt collectors....more
The CFPB has adopted its long-awaited final rule setting forth the procedures it will use to supervise nonbanks engaged in conduct that poses risks to consumers. The final rule will be effective 30 days after its publication...more
The Consumer Financial Protection Bureau has adopted a final rule setting forth the procedures it will use to supervise nonbanks engaged in conduct that poses risk to consumers....more
Last week, in its decision in American Express Co. v. Italian Colors Restaurants, the U.S. Supreme Court delivered a knock-out punch to the last major court challenge to the use of class action waivers in consumer arbitration...more
The Office of the Comptroller of the Currency (OCC) recently updated its guidance on procedures for internal appeals of supervisory decisions at various levels. The subject matter deals solely with internal appeal procedures...more
The Truth in Lending Act (TILA) ban on mandatory arbitration provisions in certain mortgage loans becomes effective on June 1, 2013. Lenders now using mortgage loan documentation containing such provisions should take steps...more
The CFPB has issued a proposal to temporarily delay the June 1, 2013 effective date of the Regulation Z prohibition on financing credit insurance premiums (Section 1026.36(i)). The proposal responds to concerns raised by...more
Last Friday, the CFPB simultaneously issued a final rule to govern the administration of the Bureau’s Civil Penalty Fund (CPF) and proposed revisions to that rule. The final rule is effective immediately upon publication in...more
Last April, the CFPB announced that it was beginning its study of consumer arbitration as mandated by Section 1028 of the Dodd-Frank Act. Last week, nearly a year after that announcement, David Silberman, the CFPB’s Associate...more
The Consumer Financial Protection Bureau’s second annual report to Congress on enforcement of the Fair Debt Collection Practices Act (FDCPA) confirms that debt collection will continue to be a major CFPB focus in 2013....more
The Consumer Financial Protection Bureau has issued a proposal to supervise nonbank servicers of private and federal student loans who qualify as “larger participants” in the student loan servicing market. Comments on the...more
Whatever hope President Obama may have had that his nomination of Richard Cordray to serve a five-year term as Director of the CFPB vanished today when 43 Republican Senators joined in a letter to the President saying that...more
The CFPB has issued its semiannual regulatory agenda which identifies seven regulatory matters that the CFPB “reasonably anticipates” having under consideration during the period from October 1, 2012 to October 1, 2013....more
Significant changes to Pennsylvania banking laws will take effect on December 24, 2012, as a result of three bills, known as the “Banking Law Modernization Package,” signed into law by Governor Tom Corbett....more