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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

Speaking Multiple Languages Is Great for Business, but Do You Know When You Are Required to Provide Translated Documents?

The United States is a big melting pot of cultures, ethnicities, and languages. This diversity is great for business, but if you are advertising that your business speaks "Spanish" or that your business can assist customers...more

Breaking Barriers: Language Access Programs and the New Landscape for Businesses

Today, in the United States, the number of people who speak Spanish or a language other than English is growing rapidly. According to the United States Census, about 68 million people do not speak English at home....more

CFPB Bites of the Month - 2023 Annual Review - Debt Collection

In this article, we share a timeline of our monthly "bites" for 2023 applicable to debt collection. If debt collection in 2023 had a theme it would be medical debt....more

CFPB Issues SCRA Paper Identifying Underused Benefits

A couple of months ago, the Consumer Financial Protection Bureau issued a research paper it said revealed that many active duty servicemembers who were entitled to interest rate reductions under the federal Servicemembers...more

CFPB Relies on Questionable Premise in Bulletin About Repossession

In February, the Consumer Financial Protection Bureau issued a compliance bulletin to the vehicle finance industry to make sure that industry participants—including and especially servicers—remember the CFPB's authority to...more

CFPB Data Point Studies Subprime Financing Rates and Default Risks Across Creditor Types

Every creditor with subprime customers has experienced—on one occasion or another, we expect—someone judging it unfavorably for allegedly taking advantage of consumers by charging higher interest rates. That "tsk-tsk"...more

More SCRA Enforcement Activity by the Department of Justice

The Servicemembers and Veterans Initiative at the U.S. Department of Justice continues. At the end of July, the DOJ entered into a consent order in a Texas case where a towing company sold active-duty servicemembers' cars...more

Statutes of Limitations: Some Guidance for Vehicle Finance from the Ninth Circuit

Many finance companies, debt buyers, debt collectors, and collection law firms wrestle with the question of which statute of limitations to apply when collecting a deficiency balance on a retail installment contract. States...more

Department of Justice Remains Focused on SCRA Enforcement

The U.S. Department of Justice continued the pursuit of its civil rights initiatives aimed at enforcement of federal laws that protect servicemembers, veterans, and their families in September by settling with the City of San...more

Servicing Customers Affected by Natural Disasters: Tips for Unsecured and Personal Property Secured Creditors to Prepare for the...

Over the past six months or so, creditors, servicers, and debt collectors alike have been forced to revisit disaster management policies in light of the unique and far-reaching impact of COVID-19: it is at once a nationwide...more

Towing Companies Sued for Alleged SCRA Violations

In mid-August, the Department of Justice sued Target Recovery Towing Inc. and Target Recovery & Transport Inc. in Florida federal court for violating the federal Servicemembers Civil Relief Act when, without a court order,...more

CFPB Proposes Time-Barred Debt Disclosures

As a supplement to its notice of proposed rulemaking on debt collection, on February 21, 2020, the Consumer Financial Protection Bureau issued additional proposed rules addressing attempts to collect debts for which the...more

Bankruptcy Court Grants Relief from Stay When Debtors Fail to Redeem Pledged Collateral in Title Pawn Transactions

Secured creditors must be ever mindful of their rights in consumer bankruptcy cases. Details that might seem technical or insignificant can mean the difference between a creditor's obligation being secured and being...more

Lien Filing Error Renders Creditor's Claim Unsecured

Many steps creditors take in the process of directly or indirectly originating a vehicle finance agreement are designed to protect the creditor in the event its credit risk assessment was off and the consumer defaults. A...more

What's Missing? The CFPB's Notice of Proposed Rulemaking on Debt Collection Fails to Resolve a Number of Compliance Issues

This article is part of a series of articles and webinars Hudson Cook will present over the coming weeks addressing the CFPB's Notice of Proposed Rulemaking on Debt Collection (the "Proposals"). While the Proposals, if...more

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