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CFPB Bites of the Month - 2024 Annual Review - Debt Collection

In this article, we share a timeline of our monthly "bites" for 2024 applicable to debt collection practices. Like 2023, the theme of 2024 was medical debt collection....more

CFPB Bites of the Month: A December to Remember

In this month's Top 10 article, we share some of our top "bites" for the prior month covered during the December 21, 2022, webinar. So, what happened last month?...more

CFPB Claims that Discrimination Is a UDAAP

The Consumer Financial Protection Bureau recently announced that discrimination—whether intentional or unintentional but produces a discriminatory outcome—is an unfair, deceptive, or abusive act or practice ("UDAAP") under...more

CFPB Sues Software Company for Providing Substantial Assistance to Unlawful Credit Repair Businesses

The Consumer Financial Protection Bureau recently filed a lawsuit in federal district court accusing a California-based software company and its founder, owner, and CEO of providing substantial assistance to illegal credit...more

GAP Benefits and Refunds: Seems Like the Repeat Button Is On

I had a roommate in college who was extremely proud of his new stereo system with its three-foot-tall speakers. It was a state-of-the-art system at the time, with crystal clear sound and thumping bass. He'd often play the...more

CFPB Bites of the Month - December Top 20

Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the CFPB to be considered by financial services providers. It was a particularly busy month at the CFPB, so as an extra...more

Car Buyer Granted Default Judgment Against Dealership for Violations of TILA, Connecticut Retail Installment Sales Finance Act,...

A consumer saw a 2012 BMW 750i listed for sale for $15,900. After he visited the dealership, test-drove the BMW, and completed a credit application, the salesman told him that the car price was $16,500, explaining that the...more

Menu? We Don't Need No Stinkin' Menu. Yes, You Do!

As you know, the pandemic shelter-at-home orders forced the closing of dealerships across the country. I suspect that the new ways dealerships have developed to continue to move the metal have inspired some dealerships to...more

CFPB Issues Policy Statement on 'Abusiveness': A Step in the Right Direction?

On January 24, the CFPB issued a Policy Statement to provide clarification on how it will apply the "abusiveness" standard in supervision and enforcement matters. As you may know, the Dodd-Frank Act provides that the CFPB may...more

Actions Speak Louder than Words

One of my all-time favorite sayings is “actions speaker louder than words.” Or, in other words, what you do has a stronger impact on people than what you say.  I can think of no better application of that maxim than to the...more

In Times of Peace, Prepare for War

I just finished up a very active conference season. I’ve been on the “conference circuit” as some would say, since early January. Being on the conference circuit has enabled me to re-connect with friends, colleagues, clients...more

It's 10 P.M. Do You Know What Your Repossession Agents Are Doing?

Do you truly know what the repossession agents you’ve assigned to repossess one or more of your cars for you are doing? I’m hearing more and more about a very disturbing practice in the repossession services industry that,...more

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