Remove 2016 02
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CFPB Amends its Vendor Management Guidance

Consumer Financial Services Law

According to the CFPB, the amendment was necessary to “clarify that the depth and formality of the risk management program for service vendors may vary depending upon the service being performed – its size, scope, complexity, importance and potential for consumer harm.” CFPB Bulletin 2016-02.

Banks 40
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Pennsylvania District Court Applies Benign Language Exception to Barcode

Consumer Financial Services Law

15-4968 , 2016 U.S. at 50097-02, 50108. A Pennsylvania district court has recognized that a benign language exception exists under 15 U.S.C. 1692f(8) and may be applied to barcodes under appropriate circumstances. Anenkova v. Van Ru Credit Corp. , LEXIS 108950(E.D. Convergent Outsourcing , 765 F.3d 3d 299 (3 rd Cir. 1692f(8).

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Will Hunstein Require a Reset?

Consumer Financial Services Law

As early as 2012, the CFPB recognized that the use of service providers “is often an appropriate business decision.” CFPB Bulletin 2012-03; see also CFPB Bulletin 2016-02. The CFPB has always understood and contemplated the use of third-party vendors.