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Federal Bank Regulatory Agencies Issue Final Joint Guidance for Managing Third-Party Relationship Risks

On June 6, 2023, the Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, and the Office of the Comptroller of the Currency issued final joint guidance addressing bank management of...more

New California Law Impedes Creditors' Ability to Offer Voluntary Protection Products to Military Servicemembers

California recently enacted Senate Bill 1311, the Military and Veteran Consumer Protection Act of 2022, with the stated intent of strengthening the state's military consumer protection laws by enhancing protections for...more

States Are Joining the War on Voluntary Protection Products

When it comes to voluntary protection products, such as guaranteed asset protection, debt cancellation, credit insurance, service contracts, and vehicle protection products, the hottest topic this summer seems to be the...more

Voluntary Protection Products: A Matter of "Interest" for State and Federal Regulators

Voluntary protection products like credit insurance, debt protection, GAP, service contracts and motor clubs, have gained increased attention by state and federal regulators overseeing the consumer finance industry....more

GAP Refunds: What's Old is New Again

Over the last decade, as more and more states have enacted laws governing guaranteed automobile protection products, compliance with state GAP laws has been a regular topic of discussion between consumer financial services...more

Creditors Must Consider Impact of COVID-19 on Administration of Voluntary Protection Products

In response to the COVID-19 pandemic, creditors across the country continue to strive to balance business continuity challenges and servicing immediate consumer financial needs with public safety. Many creditors have begun...more

COVID-19 Payment Accommodations from the Perspective of Voluntary Protection Product Providers

In response to the COVID-19 pandemic, creditors across the country are working to balance their business operations and servicing immediate consumer financial needs with public safety. Some creditors have begun offering...more

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