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April Report Reveals Substantial Decrease in Consumer Litigation Filings

According to a recent report by WebRecon, the month of April saw a significant reduction from the previous month in filings under the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), and the...more

CFPB Issues Advisory Opinion on “Zombie Debt”

On April 26, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion reminding the industry that a debt collector who brings or threatens to bring a foreclosure action to collect a time-barred...more

Report Shows Steep Rise in Consumer Complaints to CFPB: Consumer Reporting Leads the List While Debt Collection Declines

The U.S. PIRG Education Fund (PIRG) released a report analyzing consumer complaints submitted to the Consumer Financial Protection Bureau (CFPB) in 2021 and 2022. The report noted that consumer complaint totals set a new...more

Double Reporting Leads to Denial of Summary Judgment in Illinois FCRA Case

An Illinois federal district court recently denied a creditor-defendant’s motion for summary judgment in a Fair Credit Reporting Act (FCRA) case brought by a consumer who questioned why his debt was being reported twice — as...more

CFPB Report Finds Decline in Debt in Collections Appearing on Consumer Reports

On February 14, the Consumer Financial Protection Bureau (CFPB) released a report entitled Market Snapshot: An Update on Third-Party Debt Collections Tradelines Reporting. The report sought to examine trends in the reporting...more

Eleventh Circuit En Banc Panel Reverses Controversial Hunstein Decision

In a much anticipated decision released September 8, an en banc panel of the Eleventh Circuit Court of Appeals reversed the district court’s decision that a debt collector’s outsourcing of its letter process to a third-party...more

Recent CFPB Advisory Opinion Puts Pay-to-Pay Fees in Crosshairs

“Convenience” fees charged to consumers for the use of certain debt payment options have come under increased scrutiny, as regulators have sought to limit charges and other back-end fees that may come as a surprise to...more

CFPB Targets Convenience Fees in Latest Advisory Opinion

On June 29, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion focused on consumer debt collectors and the convenience fees they charge for some payments, such as online or by phone....more

Hunstein Oral Arguments: Eleventh Circuit Weighs Use of Third-Party Vendors in Debt Collection

On February 22, the Eleventh Circuit Court of Appeals held oral argument in Hunstein v. Preferred Collection and Management Services Inc. (Case Number 19-14434). Almost a year ago, on April 21, 2021, the Court of Appeals...more

Year-End Report Reveals Continuing Trend of Increased FCRA Filings in 2021

According to a recent year-in-review report by WebRecon, Fair Credit Reporting Act (FCRA) filings continued their upward trajectory throughout 2021. This stands in contrast to filings under the Fair Debt Collection Practices...more

New York Enacts Consumer Credit Fairness Act, Amending Civil Practice Law and Rules and the Judiciary Law

On November 8, New York Governor Kathy Hochul signed into law the Consumer Credit Fairness Act (Act) (Legislation S.153/A.2382). The Act amends provisions of New York’s Civil Practice Law and Rules, commonly referred to as...more

New Debt Collection Rule to Take Effect November 30, 2021

On October 30, 2020, the Consumer Financial Protection Bureau (CFPB or the Bureau) released its long-awaited final debt collection rule — also known as Regulation F. The Bureau supplemented the rule on December 18, 2020 and...more

Second Circuit Holds Reporting a Judgment as “Satisfied” was Accurate and Provides Guidance on Defending Claims for Willfully...

The Second Circuit Court of Appeals recently upheld a ruling that reporting a judgment as “satisfied” was accurate under the Fair Credit Reporting Act (FCRA) when the underlying lawsuit was dismissed by stipulation as...more

CFPB Signals Enforcement Priorities with Release of 2020 Consumer Complaints Report

On March 24, the Consumer Financial Protection Bureau (CFPB) provided the Consumer Response 2020 Annual Report (CFPB Report) to Congress. The CFPB Report reflects complaints submitted by consumers to the CFPB and analyzes...more

Tradeline Status Not Threatening Imminent Legal Action Is Not a FDCPA Violation

In Guzman v. I.C. Sys., 2021 U.S. Dist. LEXIS 42595, 2021 WL 861914 (E.D.N.Y. Mar 8, 2021), Carolina Guzman (plaintiff) alleged that I.C. System, Inc. (defendant) violated the FDCPA by reporting to Experian that her debt to...more

2020 Consumer Financial Services Year in Review & A Look Ahead

2020 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Pepper is uniquely positioned to help its clients find successful resolutions...more

CFPB Investigating Venmo’s Funds Transfer and Debt Collection Policies

In a recently filed Form 10-K, PayPal Holdings, Inc. (PayPal) announced that it received a Civil Investigative Demand (CID) from the Consumer Financial Protection Bureau (CFPB) on January 21 “related to Venmo’s unauthorized...more

CFPB Signals Possible Delays Regarding Qualified Mortgage and Debt Collection Rules

The Consumer Financial Protection Bureau (CFPB) signaled Thursday that it may seek to delay implementation of the agency’s recently completed qualified mortgage and debt collection rules. Although the qualified mortgage rule...more

Factually v. Legally Inaccurate Information, The Difference Matters: Court Rejects FCRA Claims Based on Disputed Legal Issue

On January 21, 2021, the United States District Court for the Northern District of Illinois granted TransUnion Data Solutions LLC’s (Trans Union) motion for judgment on the pleadings, denying Blue Sobenes’ (Sobenes) claims...more

Second Circuit Holds a Threat of Suit Without Further Notice May Overshadow Consumer’s Validation Rights

Reversing a district court’s dismissal for failure to state a claim under the Fair Debt Collection Practices Act (“FDCPA”), the Second Circuit (“the Court”) ruled in Mizrachi v. Wilson, Elser, Moskowitz, Edelman & Dicker LP...more

Debt Collector Agrees to Independent Consultant, Regular Review in FCRA Settlement

Following a Consumer Financial Protection Bureau (“CFPB”) investigation into its credit reporting procedures, telecommunications debt collector Afni, Inc. agreed Thursday to implement additional safeguards against inaccurate...more

Winnowed TCPA Survives Constitutional Challenge Before U.S. Supreme Court

The United States Supreme Court issued its much-awaited decision in Barr v. American Association of Political Consultants on Monday, July 6, striking down the government-backed debt exemption in the Telephone Consumer...more

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