Troutman Sanders

OCTOBER 30, 2023

The FTC’s Safeguards Rule requires nonbanking financial institutions, such as mortgage brokers, motor vehicle dealers, and payday lenders, to develop, implement, and maintain a comprehensive security program to keep their customers’ information safe. For more information, click here. For more information, click here. On October 26, the U.S.

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Consumer Financial Services Law

APRIL 22, 2021

While it is a powerful tool, it shines a bright light on a debt collector’s policies and procedures and therefore, the stakes are high. If a debt collector’s policies are adjudicated to be lacking, it can expose the debt collector to liability not only in the present action, but potentially to a swarm of further litigation.

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Troutman Sanders

FEBRUARY 21, 2024

The updated rule broadens the CFPB officials eligible to evaluate appeals, the options for resolving an appeal, the matters subject to appeal, and makes additional clarifying changes. On February 16, the CFPB reported on the first set of results from the newly updated Terms of Credit Card Plans survey. economy.

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Troutman Sanders

JULY 18, 2022

Federal Activities: On July 13, the Federal Trade Commission (FTC) published its proposed Motor Vehicle Dealers Trade Regulation Rule in the Federal Register. The deadline to submit comments is September 12. Department of the Treasury published a request for comment (RFC), seeking input on U.S. For more information, click here.

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Consumer Financial Services Law

MARCH 22, 2021

The final debt collection rule interprets the definition of a consumer to include deceased natural consumers, as well. Looking towards a November 30 th effective date, here are some key items that may require adjustments to your policies and procedures. See Comment 10(b)(2)-1. Initial Skip Traces. Location Information.

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Troutman Sanders

JUNE 14, 2023

On June 8, the board of governors for the Federal Reserve (the Fed), Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), and the OCC requested public comment on proposed guidance addressing reconsiderations of value (ROV) for residential real estate transactions.

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Fico Collections

DECEMBER 20, 2021

The past year was one of transition in the Washington, DC policy arena as a new President, Congress and group of banking agency heads took charge of the financial legislative and regulatory policy agenda. with New Rules Promulgated by the CFPB. Despite a Wave of New Product Innovations, New Overdraft Rules Are on the Way.

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Troutman Sanders

FEBRUARY 6, 2024

On February 2, House Representatives Patrick McHenry, French Hill, and Andy Barr sent a letter to Federal Deposit Insurance Corporation (FDIC) Chairman Martin Gruenberg, expressing concern about a shift in regulatory posture having a chilling effect on banks’ engagement with fintech. For more information, click here.

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Collection Industry News

FEBRUARY 15, 2021

On January 26, 2021, the FTC sent its annual letter to the CFPB reporting on the FTC’s activities related to the Equal Credit Opportunity Act (“ECOA”) and Regulation B. The Bureau leverages the FTC’s annual letter for its own Annual Report to Congress on ECOA. Court of Appeals for the Second Circuit in Tewinkle v.

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Troutman Sanders

OCTOBER 17, 2022

This letter follows Chairman Clyburn’s May 2022 letters to the NCRAs, requesting information on the companies’ efforts to respond to and resolve credit reporting inaccuracies raised by consumers during the pandemic. For more information, click here. For more information, click here. For more information, click here. and the U.S.,

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Collection Industry News

SEPTEMBER 29, 2020

ACA International Leadership to Discuss its Comments on the Proposed Rule in Press Briefing Today. As the leading voice of the ARM industry, ACA International submitted more than 150 pages of comments Sept. 17, 2019 on the CFPB’s Notice of Proposed Rulemaking for the Fair Debt Collection Practices Act of 1977.

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Troutman Sanders

JANUARY 23, 2023

Notably, FinCEN alleged that public reporting demonstrated that Bitzlato did not effectively implement policies and procedures designed to combat money laundering and illicit finance. On January 18, the CFPB released the updated “Mortgage Servicing Examination Procedures,” providing transparency to stakeholders about how we do our work.

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Consumer Financial Services Law

NOVEMBER 19, 2020

On October 30, 2020, the CFPB published its long awaited Final Debt Collection Rule (the “Rule”) which is intended to interpret the federal Fair Debt Collection Practices Act (the “FDCPA”) and clarify how new communication technologies can be used in compliance with the FDCPA. What’s Not Included in the Rule?

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Troutman Sanders

JULY 11, 2023

To help you keep abreast of relevant activities, below find a breakdown of some of the biggest events at the federal and state levels to impact the Consumer Finance Services industry this past week: Federal Activities State Activities Federal Activities: On July 7, the Consumer Financial Protection Bureau (CFPB), U.S.

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Troutman Sanders

NOVEMBER 29, 2021

Federal Activities: On November 23, the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency issued a statement summarizing their interagency “policy sprints” focused on crypto assets and providing a roadmap of future work related to crypto assets.

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Consumer Financial Services Law

FEBRUARY 17, 2021

Enloe While it remains to be seen what, if any, changes a change in leadership in the CFPB will bring to the Debt Collection Rule, for now collection agencies should begin readying themselves for a November 30 th effective date. Under the CFPB’s interpretation this would include executors, administrators and personal representatives.

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Katabat

AUGUST 4, 2021

The CFPB Confirms Nov. 30, 2021 Effective Date for Debt Collection Final Rules. The Consumer Financial Protection Bureau (CFPB) has announced that two final rules issued under the Fair Debt Collection Practices Act (FDCPA) will take effect as planned, on November 30, 2021.

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Katabat

AUGUST 4, 2021

The CFPB Confirms Nov. 30, 2021 Effective Date for Debt Collection Final Rules. The Consumer Financial Protection Bureau (CFPB) has announced that two final rules issued under the Fair Debt Collection Practices Act (FDCPA) will take effect as planned, on November 30, 2021.

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Troutman Sanders

FEBRUARY 23, 2022

Federal Activities: On February 18, the Consumer Financial Protection Bureau (CFPB) released a bulletin, detailing student loan servicers’ obligation to halt unlawful conduct on borrowers’ eligibility and benefits under the Public Service Loan Forgiveness Waiver. The petitions will be posted on public dockets for review and comment.

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Troutman Sanders

JANUARY 30, 2023

In 2021, the Office of Comptroller of Currency (OCC) issued Interpretive Letters 1174 and 1179 , governing the permissibility of national banks to issue dollar tokens. On January 26, the Office of Science and Technology Policy (OSTP) issued a notice of request for information (RFI) that recommended the U.S. On January 26, U.S.

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Consumer Financial Services Law

JANUARY 21, 2018

On November 24, 2017, the White House appointed Mick Mulvaney as acting director of the CFPB, effective November 27, 2017. Here is a quick look at the actions of the agency since Mulvaney’s appointment: December 2017 : The CFPB has changed its mission statement. emphasis supplied). The question becomes: will they go too far?

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Troutman Sanders

JANUARY 25, 2021

Our bank and loan servicing clients also face novel challenges affecting their industry due to COVID-19, particularly the ever-changing rules and regulations concerning evictions and foreclosures. The president appointed David Ueijo, who previously acted as the CFPB’s chief strategy officer, to serve as the acting director.

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Troutman Sanders

JUNE 1, 2021

Our bank and loan servicing clients also face novel challenges affecting their industry due to COVID-19, particularly the ever-changing rules and regulations concerning evictions and foreclosures. Comments on the proposed changes are requested within 60 days of publication in the Federal Register, which is expected shortly.

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Troutman Sanders

FEBRUARY 13, 2024

The defendants and the CFPB jointly agreed to the dismissal of their respective appeals. On February 8, a New York bankruptcy judge ruled against cryptocurrency exchange Gemini’s claim that it has a secured claim on more than $800 million in Genesis Global Capital assets. They also argue that the Final Rule is arbitrary and capricious.

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Troutman Sanders

AUGUST 28, 2023

Thompson, and CFPB Director Rohit Chopra will participate in a roundtable discussion on September 12, at 3:00 p.m. On August 22, the CFPB filed an opposition to a motion made by a group of intervenors seeking to expand the scope of a preliminary injunction issued by the U.S. Fudge, Acting Comptroller of the Currency Michael J.

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Troutman Sanders

OCTOBER 24, 2023

The proposed Personal Financial Data Rights rule activates a dormant provision of law enacted by Congress more than a decade ago. The proposed rule would allow people to break up with banks that provide bad service and would forbid companies that receive data from misusing or wrongfully monetizing the sensitive personal financial data.

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Troutman Sanders

MARCH 15, 2021

Our bank and loan servicing clients also face novel challenges affecting their industry due to COVID-19, particularly the ever-changing rules and regulations concerning evictions and foreclosures. For more information, click here. For more information, click here. On March 9, the Office for Civil Rights at the U.S.

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Troutman Sanders

MAY 3, 2021

Our bank and loan servicing clients also face novel challenges affecting their industry due to COVID-19, particularly the ever-changing rules and regulations concerning evictions and foreclosures. Federal Activities: On May 3, the Consumer Financial Protection Bureau’s (CFPB) interim final rule goes into effect.

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Consumer Financial Services Law

JANUARY 22, 2021

Enloe On December 18, 2020, the CFPB published the remainder of its Final Debt Collection Rule (the “Rule”) highlighting its crown jewel - the provisions centering around debt validation notices. The entire Rule (both Parts 1 and 2) takes effect November 30, 2021. By Caren D. Section 1006.2(c) Section 1006.26

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Troutman Sanders

APRIL 11, 2022

dollar-based stablecoin system and policy considerations regarding stablecoin stability, interoperability, and separability. The proposed rule would protect human trafficking survivors by preventing CRAs from including negative information resulting from abuse. Specifically, HHS seeks comment on Section 13412 and Section 13410(c)(3).

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Troutman Sanders

SEPTEMBER 5, 2023

On August 30, the Consumer Financial Protection Bureau (CFPB) issued a Consumer Advisory notifying consumers about actions they should take when their home insurance policy is cancelled or if the cost of the policy becomes unaffordable. For more information, click here. For more information, click here. On August 29, the U.S.

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Troutman Sanders

APRIL 26, 2021

Our bank and loan servicing clients also face novel challenges affecting their industry due to COVID-19, particularly the ever-changing rules and regulations concerning evictions and foreclosures. The proposed rule also describes the provisions required in those agreements and specifies regulatory reporting treatment. State Activities.

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Troutman Sanders

NOVEMBER 16, 2020

Our bank and loan servicing clients also face novel challenges affecting their industry due to COVID-19, particularly the ever-changing rules and regulations concerning evictions and foreclosures. Public policy innovators are also calling for “more tools to help create a ‘healthy internet.’” ” For more information, click here.

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Troutman Sanders

JULY 19, 2023

During September 2023, the FSB and the International Monetary Fund (IMF) are expected to release a joint paper that synthesizes the policy findings from IMF work on macroeconomic and monetary issues and the FSB’s work on supervisory and regulatory issues. For more information, click here. For more information, click here. Ripple Labs, Inc. ,

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Troutman Sanders

MAY 24, 2021

Our bank and loan servicing clients also face novel challenges affecting their industry due to COVID-19, particularly the ever-changing rules and regulations concerning evictions and foreclosures. The letter highlights the risk of granting charters to nonbanks and the need to protect consumers and the banking system.

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