DE Under 3: Court Held That Workday Was an “Agent” to Employers Licensing its AI Applicant Screening Tools
Business Associates Here, There, and Everywhere: When Does Your Service Provider Really Need to Sign a HIPAA Business Associate Agreement?
In House Counsel: How To Measure the Effectiveness of Your Staffing Strategy
Sitting with the C-Suite: Identifying Opportunities to Leverage Human Capital
The CCPA for the Land Title Industry: Service Providers and Sale of Data Under the CCPA
Podcast - Risk Management: Troubleshooting & Problem Solving
Cybersecurity in the investment management industry
FCPA Compliance and Ethics Report-Episode 157-Training of Third Parties Under the FCPA
Special Report: The Hot-ish Swag at LegalTech New York 2015
The debt settlement industry is fast emerging as a significant portion of the overall consumer financial services market, yet many still do not understand the space. Please join Hudson Cook partner Cathy Brennan as she...more
Banking regulators have issued a joint statement outlining the potential risks that financial institutions face in arrangements with third parties to deliver bank deposit products and services and examples of risk management...more
On June 17, 2024, FHA announced in draft Mortgage Letter 2024-12 a proposed revision to its Defect Taxonomy to clarify that fraud or material misrepresentation involving a sponsored Third-Party Originator (TPO) is a Tier 1...more
Sometimes you hear grumbling that Leap Day shouldn’t mean an extra day of work – but not at the CFPB. The agency celebrated Feb. 29 this year by issuing guidance regarding “steering.”...more
On January 9, 2024, the California Department of Financial Protection and Innovation (DFPI) announced that it entered into a consent order with a Delaware fintech company that provided California consumers with access...more
In this final edition of the year, we cover the following issues of import for educational institutions: - CFPB scrutiny of college-sponsored financial products; - Changes ahead for Title IV program participants and...more
On February 15, Federal Reserve Board Governor Michelle W. Bowman delivered remarks at the Midwest Cyber Workshop, during which she discussed topics related to third-party service provider reliance and regulatory expectations...more
On August 10, the CFPB issued an interpretive rule stating that digital marketing providers that are involved in the identification or selection of prospective customers or the selection or placement of content to affect...more
Consumer debt collectors may not be permitted to charge consumers “convenience fees” for card payments, which the Consumer Financial Protection Board (the “CFPB”) calls “pay-to-pay” fees, unless the underlying loan agreement...more
The Consumer Financial Protection Bureau's Compliance Bulletin and Policy Guidance; 2016-02, Service Providers addresses the CFPB's expectation that companies oversee their business relationships with service providers in a...more
Call for input: Industry needs to engage as the FCA moves forward on its transformative vision for open finance. Imagine a world in which you could access your bank accounts, credit cards, mortgage, pensions, savings...more
Google has updated its financial products and services policy to restrict the advertisement of debt settlement, debt management services, and credit repair services....more
The CFPB’s fourth biennial report on the credit card market was issued at the end of August. The Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act) requires the CFPB to perform periodic market...more
The CFPB has issued a new report on tradelines reported by third-party debt collectors as reflected on credit reports compiled by nationwide consumer reporting agencies. The third-party collector tradelines consist of those...more
On June 14, 2019, Texas Governor Greg Abbott signed HB 996, which amends Chapter 392 of the Texas Finance Code dealing with debt collection. The amendments are effective September 1, 2019. ...more
On May 7, 2019, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (the Proposed Rulemaking) to implement portions of the Fair Debt Collection Practices Act (FDCPA)....more
The CFPB has announced that it will hold a Town Hall to take place in Philadelphia, Pennsylvania beginning at Noon on May 8, 2019....more
The Student Borrower Protection Center (SBPC)—an organization established by former CFPB Student Loan Ombudsman Seth Frotman—recently published an article examining the Department of Education’s oversight of “lead...more
The OCC and CFPB consent orders issued against Wells Fargo on April 20 cited deficiencies in third-party oversight practices. The orders are the latest additions to an ever-expanding body of agency enforcement actions...more
On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more
Last week, at the Consumer Advisory Board Meeting in Washington D.C., Consumer Financial Protection Bureau (CFPB) Director Richard Cordray provided an update on one of the most highly anticipated areas in the debt collection...more
The Fourth Circuit recently examined the issue of Article III standing in the context of the FDCPA. In Ben-Davies v. Blibaum & Associates, P.A., 2017 U.S. App. LEXIS 9667 (4th Cir. June 1, 2017), the consumer sought to...more
Those engaged in the business of selling consumer debt or of purchasing delinquent consumer debt for collection purposes are well-advised to take heed of the recent developments on the judicial and legislative fronts that...more
On July 28, 2016, the Consumer Financial Protection Bureau (CFPB) released an outline of proposals and alternatives under consideration for regulating debt collection practices. The outline’s release triggers the formation of...more
July 28th, the CFPB held a field hearing in Sacramento, California on debt collection that coincided with its release of an outline of the proposals it is considering in connection with its debt collection rulemaking. In his...more