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The CFPB’s final collections rule: meaningful attorney involvement safe harbor removed; debt sale restrictions modified

Our blog post series has detailed a number of ways in which the CFPB’s final debt collection rule departs from last year’s NPRM. There are two additional topics approached very differently in the final rule: (1) the proposed...more

CFPB, FTC, and Others Partner to Target Phantom and Abusive Debt Collection

On September 29, the CFPB, in partnership with the FTC and numerous federal and state law enforcement agencies, announced a nationwide effort addressing “phantom debt collection” and abusive and threatening debt collection...more

CFPB, FTC and others partner to target phantom and abusive debt collection

On September 29, the CFPB, in partnership with the FTC and numerous federal and state law enforcement agencies, announced a nationwide effort addressing “phantom debt collection” and abusive and threatening debt collection...more

FTC Launches Military Consumer Data Dashboard

The Federal Trade Commission (FTC) has launched a new online “dashboard” that makes certain data received from active duty servicemembers and veterans publicly available. ...more

Debt Collector Enters into Consent Order with CFPB to Settle Alleged FDCPA and UDAAP Violations

Last week, the CFPB announced that that it had entered into a consent order with an Illinois-based debt collection company. According to the settlement, the company’s business consists primarily of purchasing and then...more

Department of Defense Proposes Data Sharing Arrangement with Department of Education to Identify Service Members Eligible for 0%...

A Federal Register entry published last week details a proposed data-sharing arrangement between the Department of Defense (DoD) and the Department of Education (DoE) designed to reduce the amount of interest that certain...more

CFPB Makes Changes to Advisory Committee Charters and is Accepting New Membership Applications

The CFPB has announced a number of changes to its advisory committee charters, publishing notices in the Federal Register on March 22 pertaining to each advisory committee: the Consumer Advisory Board (CAB), Community Bank...more

Regulation CC Amendments Proposed and Comment Period Reopened for Amendments Proposed in 2011

On November 20, the Federal Reserve Board (FRB) and CFPB jointly proposed amendments to Reg. CC, which implements the Expedited Funds Availability Act (EFA Act), and also reopened for public comment various amendments that...more

Democratic Senators Urge Mulvaney To Reconsider MLA Supervision Policy Change

In response to reports that Acting CFPB Director Mick Mulvaney intends to dispense with routine supervisory examinations of creditors for violations of the Military Lending Act (MLA), Senate Democrats sent a joint letter...more

DOJ brings suit against indirect auto lender alleging its repossession practices violated the SCRA

On March 28, the Department of Justice (DOJ) brought another lawsuit against an auto finance company alleging the company violated the Servicemembers Civil Relief Act (SCRA) by repossessing vehicles owned by servicemembers...more

Update to MLA Website Expands Search Functionality

Yesterday, the Department of Defense’s (DoD) Military Lending Act website was temporarily taken offline to accommodate various “security and performance enhancements.” ...more

Department of Defense Issues Additional MLA Rule Interpretive Guidance; SCRA Foreclosure Protections Extended

Last week the Department of Defense (DoD) issued an interpretive rule under the DoD’s Military Lending Act final rule (MLA Rule). The interpretive rule amends four of the “Q&A” format interpretations that DoD issued on August...more

CFPB Releases Summer 2017 Supervisory Highlights

Earlier this week the CFPB released its Summer 2017 Supervisory Highlights, which covers supervisory activities generally completed between January through June of 2017. The report touts the $14 million total restitution...more

FTC Releases Agenda And Panelists For Upcoming Military Consumer Financial Workshop

On July 19, the Federal Trade Commission will hold a workshop in San Antonio titled the “2017 Military Consumer Financial Workshop: Protecting Those Who Protect Our Nation.” The FTC has uploaded an agenda and list of...more

Propoposed Bill Would Significantly Expand MLA Disclosure Requirements

We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to...more

Competing House and Senate bills aim to eliminate or reform the CFPB

Although the Trump Administration has largely been silent with respect to Dodd-Frank and the future of the CFPB, some members of Congress have been very active in proposing significant legislative changes. Several measures to...more

CFPB Focuses on Servicing in Update to Student Loan Examination Procedures

On Monday the CFPB released updated examination procedures for student loans.  This update revises and expands on a previous update that was released in December 2013 in conjunction with the CFPB’s “larger participants” rule...more

CFPB issues request for information and report in conjunction with release of proposed payday/auto title/high-rate installment...

In addition to the proposed payday loan rule released yesterday, the CFPB has issued (1) a “Request for Information on Payday Loans, Vehicle Title Loans, Installment Loans, and Open-End Lines of Credit,” and (2) a report...more

U.S. Supreme Court Hears Oral Arguments in Case to Decide Whether Loan Guarantors Are “Applicants” Under ECOA

Earlier this week the Supreme Court heard oral arguments in the case of Hawkins v. Community Bank of Raymore. We have issued an E-alert discussing this important case, which we expect will resolve whether a spouse-guarantor...more

U.S. Supreme Court Hears Oral Arguments in Case to Decide Whether Loan Guarantors Are “Applicants” Under ECOA

The U.S. Supreme Court heard oral arguments on Monday in the case of Hawkins v. Community Bank of Raymore, the result of which will determine whether a spousal guarantor is an “applicant” under the Equal Credit Opportunity...more

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