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Consumer Financial Services Spring 2018 Update

District Court Takes Expansive View of Deceptive or Misleading Practices under FDCPA - The FDCPA prohibits a debt collector from using "any false, deceptive, or misleading representation" in connection with the collection...more

District Court Holds That A Debt Collector May Not Rely On Information Provided By Creditor, Rejects Bona Fide Error Defense Claim

A District Court in the Seventh Circuit has held that a debt collector may not avail itself of the § 1692k(c) bona fide error defense if it “intentionally chose to present conflicting information,” even if that conflicting...more

Madden Fix Bill Passes House, Faces Uncertain Fate In Senate

The United States House of Representatives passed H.R. 3299, commonly known as the “Madden fix” bill, by a vote of 245-171 on February 14, 2018. The bill, which is officially entitled “Protecting Consumers’ Access to Credit...more

Seventh Circuit in Boucher: Miller Safe Harbor Language Does Not “Immunize” Debt Collectors from Liability for Violations of §...

Eighteen years ago, the Seventh Circuit crafted “safe harbor” language which, if used, shielded debt collectors from liability under 15 U.S.C. § 1692g. A recent decision, Boucher v. Fin. Sys. of Green Bay, 2018 U.S. App....more

District Court Takes Expansive View of "Deceptive or Misleading" Practices under FDCPA

The FDCPA prohibits a debt collector from using “any false, deceptive, or misleading representation” in connection with the collection of a debt. See 15 U.S.C. § 1692e. Recently, the Eastern District of New York took an...more

Congress Votes To Repeal CFPB’s Arbitration Rule

The Senate voted on Tuesday, October 24, to repeal the CFPB’s Arbitration Rule first proposed in May of 2016 and issued in its final form in July. The rule would have imposed limitations on the use of pre-dispute arbitration...more

Debtor’s Actions Immediately After Default Doom Time Barred ECOA Claim

An unpublished opinion from the Sixth Circuit provides a useful application of the statute of limitations to bar a debtor’s claims under the Equal Credit Opportunity Act, 15 U.S.C. § 1691e (“ECOA”). In Guy v. Mercantile Bank...more

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