Remove 2013 07
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What Banks and Credit Unions Need to Know: CFPB Enters into Debt Collection Consent Order

Consumer Financial Services Law

The Consent Order further reiterates the CFPB’s position that first party debt collectors, while not subject to the FDCPA, are prohibited from engaging in unfair, deceptive, or abusive acts or practices when engaged in the collection of consumer debts.

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Can Recent Enforcement Actions Provide Guidance On The CFPB’s Position On UDAAPs?

FDCPA Defense

But how can a collector know exactly what the CFPB will consider to be an “unfair” or “deceptive” or “abusive” collection practice? The CFPB has provided some guidance on UDAAPs in the bulletin it released in July 2013 and in the Examination Manual that it published in 2012. f/k/a NCO Group, Inc. (“NCO”). and Chase Bank USA, N.A.

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