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Virginia Federal Court Applies Broad Reading of Military Lending Act’s Statute of Limitation in Dismissal of Borrower Class Action

In Wood v. Omni Financial of Nevada, Inc., the plaintiffs filed a class action complaint alleging violations of the Military Lending Act (MLA). Specifically, the plaintiffs, two active duty service members who had entered...more

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

FTC Sends $3.3 Million in Payments to Customers of Passport Auto

As discussed here and here, in October 2022, the Federal Trade Commission (FTC) reached a $3.38 million settlement with Passport Automotive Group (Passport) and two of its officers over allegations that the automotive group...more

Washington Federal Court Reiterates Distinction Between Furnishers’ and CRAs’ FCRA Investigatory Obligations and the Necessity of...

A district court in the Western District of Washington held that the Fair Credit Reporting Act (FCRA) does not require a consumer reporting agency (CRA), as part of its investigative duties, to issue an opinion on the legal...more

CFPB Finds Civil Judgements Are Not Evenly Distributed

Noting a rise in credit card delinquencies, the Consumer Financial Protection Bureau (CFPB or Bureau) released a new blog post analyzing civil judgments, the final recourse for creditors to collect on unsecured debt....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

CFPB Denies Payday Lender’s Petition to Withdraw CID

Last month, the Consumer Financial Protection Bureau (CFPB or Bureau) denied Pacific Rim Alliance Corporation’s (Pacific Rim) petition to set aside a second civil investigation demand (CID) issued to the company on the basis...more

No Standing for Injunctive Relief: Eleventh Circuit Vacates Brain Performance Supplement Class Action Settlement

On April 12, the Eleventh Circuit Court of Appeals vacated an $8 million class-action settlement for lack of standing. While the issue was not raised by the district court or either party on appeal, the court ruled that the...more

What We Learned From 2022’s Top FCRA Developments

The Fair Credit Reporting Act saw no shortage of activity in 2022. That activity included judicial decisions, regulatory actions, and federal and state legislation. As we reflect on certain significant developments from the...more

CFPB Wins Big in California Federal Court: CashCall Fined $167 Million for CFPA Violations

As discussed here, in 2016 the Central District of California granted judgment in favor of the Consumer Financial Protection Bureau (CFPB) in its long-running challenge to CashCall, Inc.’s tribal-lending operation....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

No FCRA Violations Found Where Defendants Promptly Corrected Inaccurate Data and Updated Plaintiffs’ Consumer Report

In a recent decision, the U.S. District Court for the Eastern District of Pennsylvania granted summary judgment in a Fair Credit Reporting Act (FCRA) case where a bank promptly corrected inaccurate mortgage payment...more

Federal District Court Grants Summary Judgment Dismissing Claim that Creditor Conducted an Unreasonable Investigation of a FCRA...

In Suluki v. Credit One Bank, N.A. (Credit One), the Southern District of New York recently granted summary judgement to a creditor in a suit alleging violations of the Fair Credit Reporting Act (FCRA) for failure to conduct...more

New York Federal Court Partially Denies MSJ in TCPA Case Finding Possession of Cell Number Does Not Prove Consent

A federal district court in the Western District of New York recently denied in part a motion for summary judgment in a case alleging violations of the Telephone Consumer Protection Act (TCPA) based on collection calls and...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

Creditors and Employers Beware: CFPB Amends Model Background Check Form and Adverse Action Language

The Consumer Financial Protection Bureau (CFPB or Bureau) issued a final rule updating, among other things, the model form for the Fair Credit Reporting Act (FCRA) Summary of Consumer Rights and information that must be...more

FTC Orders Small Business Credit Reporting Companies to Disclose Information About Industry

The Federal Trade Commission (FTC) announced that it is launching an inquiry into the small business credit reporting industry. Specifically, it is ordering five firms to provide detailed information about their products and...more

CFPB Seeks Public Feedback About Data Brokers to Inform FCRA Rulemaking

On March 15, the Consumer Financial Protection Bureau (CFPB) issued a Request for Information (Request) seeking public comment on the business practices of data brokers and how they impact the daily lives of consumers....more

Take Two: En Banc Eleventh Circuit to Address Whether a Single Text Message Can Confer Standing Under TCPA

As discussed here, on July 27, 2022, the Eleventh Circuit Court of Appeals sua sponte vacated the district court’s approval of a $35 million class-action settlement in Drazen and Godaddy.com, LLC (Godaddy) v. Pinto. Although...more

The CFPB and FTC Continue to Focus on Tenant Screening

On February 28, the Federal Trade Commission (FTC) and Consumer Financial Protection Bureau (CFPB) jointly issued a Request for Information, seeking public comment on how background screening affects individuals seeking...more

Fourth Circuit Finds No Article III Standing in Privacy Case

A new Fourth Circuit decision has thrown out of federal court a state-law privacy claim where the plaintiff alleged only a bare statutory violation without alleging “a nonspeculative, increased risk of identity theft,”...more

TransUnion In “Active Settlement Discussions” with CFPB and FTC Over Tenant Screening

On February 14, TransUnion filed its annual 10-K report pursuant to the Securities and Exchange Act. Under the section entitled “Risks Related to Laws, Regulations and Government Oversight,” the company disclosed that it was...more

2022 Year in Review and Look Ahead Crossover With FCRA Focus - The Consumer Finance Podcast [Audio]

Please join Consumer Financial Services Partner Chris Willis in this inaugural crossover episode with Partner Dave Gettings of FCRA Focus in welcoming their guests and fellow Partners Cindy Hanson and David Anthony. Dave,...more

2022 Year in Review and Look Ahead Crossover With The Consumer Finance Podcast - FCRA Focus [Audio]

Please join Consumer Financial Services Partner Dave Gettings in this inaugural crossover episode with Partner Chris Willis of The Consumer Finance Podcast in welcoming their guests and fellow Partners Cindy Hanson and David...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

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