The Rules They Are A-Changin’: CMS Proposes a Significant Change to the 60-Day Repayment Rule
Training repayment agreements (TRAs), also known as training repayment agreement provisions (TRAPs) or "stay or pay" provisions, have made headlines recently, thanks to lawsuits from Colorado's attorney general (AG) and at...more
An Illinois federal judge has dismissed a proposed class action lawsuit that alleged that two Midwestern banks failed to provide repayment disclosures to borrowers, in a case that was unique because the CFPB came to the...more
In an unusual move, the CFPB is coming to the defense of a bank being accused of failing to provide repayment disclosures to a borrower....more
On October 25, for the sixth time since its inception, the Consumer Financial Protection Bureau ("CFPB" or "Bureau") released its biennial report ("Report") evaluating the state of the consumer credit card market. The Credit...more
On July 20, 2023, the CFPB published a report concerning the risks posed to consumers by employer-driven debt. Employer-driven debt is any form of financing arrangement where an employer extends credit or a lease to an...more
You’ve wined and dined and trained and invested in your new hire, and now they’re leaving you in the midst – before you were ready – can you still get the ring back, or in this case, “clawback” your training and other related...more
On December 9, 2020, Congressional Democrats, including Elizabeth Warren (D-Mass.) and Jerrold Nadler (D-N.Y.), proposed sweeping legislation that would overhaul consumer bankruptcy law. The proposed changes generally make it...more
On page 8 of the September–October issue, we discussed the COVID-19 forbearance landscape and related compliance challenges for mortgage servicers. In this article, we unpack the post-forbearance world, focusing on the...more
Sen. Elizabeth Warren (D-Mass.) and Sen. Sherrod Brown (D-Ohio) have released a proposal calling on Congress to provide additional protections for consumers during the COVID-19 pandemic. Their proposal notes that an...more