More on enforcement attorneys and supervisory exams
The discussions at the ABA Consumer Financial Services Winter Meeting have reached biblical proportions (literally). The participants on yesterday’s CFPB Exams and Enforcement panel read from the New...
View ArticleFTC Issues Report on Mobile Payments
The Staff Report on mobile payments recently issued by the Federal Trade Commission (FTC) focuses on areas of concern discussed at the FTC’s April 2012 workshop. The report does not break much new...
View ArticleMortgage Banking Update - March 21, 2013
In This Issue: - Uniform State Test Implementation Nearing - Mortgage Servicer's Alleged Failure To Be Licensed Subjects Company to Claims under State and Federal Debt Collection Statutes - Sixth...
View ArticleDoes the FDCPA need to get with the times?
At yesterday’s joint FTC-CFPB roundtable on the debt collection industry, the Fair Debt Collection Practices Act (“FDCPA”) was referenced together with the “1970s” a number of times. Commissioner Julie...
View ArticleDebt collection litigation: More documents or more face-to-face?
Industry representatives and consumer advocates collectively lamented the high non-appearance rate of debtors in court in debt collection cases at yesterday’s joint FTC-CFPB roundtable on the debt...
View ArticleLost in translation? Ensuring appropriate documentation in the pre-litigation...
At yesterday’s joint FTC-CFPB roundtable on the debt collection industry, industry representatives advocated for a uniform, national standard for the documentation to be provided to debtors in the...
View ArticleCalifornia Enacts New Website Disclosure Requirements
A new California law taking effect on January 1, 2014, will require any operator of a website or online service that collects personally identifiable information on state residents to include new...
View ArticleHave you been thinking about plunging into social media? Plan first.
Organizations that want to engage with tenants, decision makers, or the broader public increasingly find it important to engage through social media. Some organizations have found it necessary to have...
View ArticleThe ABA Responds on Mobile Financial Services (Plus, Apple Inc.’s “Response”)
In an interesting coincidence, the comment period for the CFPB’s Request for Information (“RFI”) on mobile financial services closed the same day, September 10th, that Apple announced “Apple Pay”—a new...
View ArticleCFPB Proposes Sweeping Changes for Prepaid Cards
The Consumer Financial Protection Bureau has issued an 870-page proposal for prepaid cards (including 156 pages of actual proposed rules) that mandates new disclosures, error resolution procedures,...
View ArticleCFPB adopts plan to publicly disclose consumer complaint narratives
The CFPB has adopted its controversial proposal to publicly disclose consumer complaint narratives in its Consumer Complaint Database. Its plans for disclosing the narratives are set forth in a final...
View ArticleN.J. Eliminates Customer Data Collection Requirements for Gift Card...
New Jersey Governor Chris Christie has signed into law an amendment to the state’s unclaimed property law—S.B. 2235—that eliminated its consumer data collection requirements. In doing so, Governor...
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