On July 14, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a status report announcing its decision not to reissue its Medical Debt Collection Advisory Opinion, which had been issued in 2024 to “remind debt...more
7/18/2025
/ Advisory Opinions ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Reports ,
Debt Collection ,
Enforcement ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Financial Services Industry ,
Healthcare ,
Medical Debt ,
Regulatory Oversight ,
Regulatory Requirements
On May 22, Illinois House Bill 3352 passed the Illinois legislature and now awaits Governor JB Pritzker’s signature. This bill amends the Illinois Collection Agency Act to provide an individual a way to avoid liability for a...more
6/12/2025
/ Coercion ,
Consumer Privacy Rights ,
Damages ,
Debt ,
Debt Collection ,
Financial Regulatory Reform ,
Financial Services Industry ,
Fraud ,
Government Agencies ,
Illinois ,
New Legislation ,
Penalties ,
State and Local Government ,
Statutory Violations
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) submitted several regulatory proposals to the Office of Management and Budget (OMB) for review. Among the rules under consideration are those related to...more
6/10/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Dodd-Frank ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Lenders ,
Mortgage Loan Originators ,
Mortgage Servicers ,
Mortgages ,
OMB ,
Proposed Rules ,
Regulation X ,
Regulation Z ,
Regulatory Agenda ,
Regulatory Oversight ,
Regulatory Reform
In a recent decision, the U.S. Court of Appeals for the Second Circuit clarified the expectations for furnishers when investigating consumer disputes under the Fair Credit Reporting Act (FCRA). In Suluki v. Credit One Bank,...more
6/5/2025
/ Appeals ,
Consumer Complaint Management ,
Consumer Financial Products ,
Credit Cards ,
Credit Reporting Agencies ,
Credit Reports ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Identity Theft ,
Investigations ,
Lenders ,
Summary Judgment
According to a recent report by WebRecon, court filings under the Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), the Telephone Consumer Protection Act (TCPA), and complaints filed with the...more
6/2/2025
/ Class Action ,
Consumer Complaint Management ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Litigation ,
Debt Collection ,
Enforcement ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Filing Requirements ,
Financial Services Industry ,
Regulatory Violations ,
TCPA
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) filed its decision to withdraw the proposed rule titled “Protecting Americans from Harmful Data Broker Practices (Regulation V)” in the Federal Register....more
5/15/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Data Brokers ,
Deregulation ,
Fair Credit Reporting Act (FCRA) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Proposed Regulation ,
Proposed Rules ,
Regulation V ,
Regulatory Reform ,
Regulatory Requirements ,
Rescission ,
Statutory Authority ,
Trump Administration
The Consumer Financial Protection Bureau (CFPB or Bureau) announced the withdrawal of 67 regulatory guidance documents, including interpretive rules, policy statements, and advisory opinions that have been issued since the...more
5/12/2025
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
ECOA ,
EFTA ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Guidance Documents ,
Military Lending Act ,
Policy Statement ,
Popular ,
Regulatory Reform ,
Regulatory Requirements ,
Rulemaking Process ,
Statutory Interpretation ,
Trump Administration ,
Truth in Lending Act (TILA)
On February 27, the Federal Trade Commission (FTC) successfully obtained a temporary restraining order against Blackrock Services, Inc. and its associated entities and individuals. The court order aims to halt the defendants’...more
3/12/2025
/ BlackRock ,
Consumer Fraud ,
Debt Collectors ,
Enforcement Actions ,
FDCPA ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
FTC Act ,
Gramm-Leach-Blilely Act ,
Misrepresentation ,
Restraining Orders ,
Statutory Violations ,
TRO ,
Unfair or Deceptive Trade Practices
In this final episode of our Year in Review series, Chris Willis is joined by colleagues David Anthony, Stefanie Jackman, and Jonathan Floyd to discuss the year in review and look ahead for debt collection. They provide...more
We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more
2/17/2025
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
Regulatory Agenda ,
Regulatory Requirements ,
TCPA ,
UDAAP ,
Uniform Commercial Code (UCC)
The Consumer Financial Protection Bureau (CFPB or Bureau) requested and was granted a 90-day stay in the litigation involving trade associations Cornerstone Credit Union League (Cornerstone) and the Consumer Data Industry...more
2/10/2025
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Reports ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Final Rules ,
Financial Services Industry ,
Medical Debt ,
Preliminary Injunctions ,
Regulation V ,
Regulatory Requirements ,
Rulemaking Process ,
Stays
On February 4, Senators Bernie Sanders (I-Vt.) and Josh Hawley (R-Mo.) introduced bipartisan legislation aimed at immediately capping credit card interest rates at 10% for a period of five years. This initiative follows a...more
On January 30, the Consumer Financial Protection Bureau (CFPB or Bureau) released its updated list of consumer reporting companies for 2025. The list includes nationwide consumer reporting companies as well as several other...more
2/4/2025
/ Consumer Credit Protection ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Consumer Reporting Agencies ,
Credit Reports ,
Data Privacy ,
Data Security ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Identity Theft ,
Reporting Requirements
This week, the U.S. Court of Appeals for the Seventh Circuit issued a decision reversing a summary judgment order in a Fair Debt Collection Practices Act (FDCPA) case. The court found that there were genuine issues of...more
1/31/2025
/ Appeals ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Debt Collectors ,
Fair Credit Reporting Act (FCRA) ,
FDCPA ,
Financial Services Industry ,
Reporting Requirements ,
Summary Judgment ,
Unfair or Deceptive Trade Practices
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) released its latest Supervisory Highlights report, focusing on the use of advanced technologies in credit scoring models. ...more
1/22/2025
/ Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Scores ,
Data Privacy ,
Data Protection ,
Discriminatory Lending Practices ,
ECOA ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Machine Learning ,
Regulatory Requirements ,
Risk Management
Recently, the Eastern District of Kentucky denied a motion to dismiss under the Fair Credit Reporting Act (FCRA) after finding the plaintiffs alleged sufficient facts to support a reasonable inference that credit reports were...more
1/8/2025
/ Class Action ,
Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Credit Reports ,
Data Privacy ,
Data Security ,
Fair Credit Reporting Act (FCRA) ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Lenders
According to a recent report by WebRecon, court filings under the Fair Credit Reporting Act (FCRA), Telephone Consumer Protection Act (TCPA), and Fair Debt Collection Practices Act (FDCPA), and complaints filed with the...more
According to a recent report by WebRecon, court filings under the Fair Credit Reporting Act (FCRA), Telephone Consumer Protection Act (TCPA), and Fair Debt Collection Practices Act (FDCPA) were down for the month. Yet,...more
On December 9, the Consumer Financial Protection Bureau (CFPB or Bureau) announced the launch of a rulemaking process addressing credit reporting on survivors of domestic violence, elder abuse, and other forms of financial...more
12/13/2024
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Coercion ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Credit Reports ,
Domestic Violence ,
Elder Abuse ,
Fair Credit Reporting Act (FCRA) ,
Financial Abuse ,
Financial Regulatory Reform ,
Financial Services Industry ,
Public Comment ,
Regulation V ,
Regulatory Agenda ,
Rulemaking Process ,
Vulnerable Victims
On December 10, the Federal Trade Commission (FTC) announced that it is distributing more than $540,000 in refunds to victims of an abusive debt collector group. The debt collectors allegedly threatened consumers with...more
On December 3, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule for public comment aimed at amending Regulation V, which implements the Fair Credit Reporting Act (FCRA). The proposed rule seeks...more
12/5/2024
/ Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reports ,
Credit Reporting Agencies ,
Data Brokers ,
Fair Credit Reporting Act (FCRA) ,
Financial Regulatory Reform ,
Financial Services Industry ,
Proposed Rules ,
Regulation V ,
Regulatory Agenda
Earlier this month, we discussed the lawsuit filed by ACA International, LLC and Collection Bureau Services, Inc. in the U.S. District Court for the District of Columbia against the Consumer Financial Protection Bureau (CFPB...more
On November 13, Representative Gary J. Palmer (R-AL) introduced House Joint Resolution 220, which seeks congressional disapproval of an advisory opinion published by the Consumer Financial Protection Bureau (CFPB or Bureau)...more
In our previous post, we discussed the New York City Department of Consumer and Worker Protection’s (NYC DCWP) decision to delay the enforcement of the amended debt collection rules from December 1, 2024, to April 1, 2025....more
Late last month, the Federal Trade Commission (FTC) filed suit against Global Circulation, Inc. (GCI) and its owner for engaging in deceptive and abusive debt collection practices. According to the FTC, the Georgia-based debt...more