On October 29, 2021 — just 32 days prior to the November 30, 2021 effective date — the Consumer Financial Protection Bureau (CFPB) released new guidance regarding the debt validation notice requirements that are part of the...more
On April 21, 2021, the U.S. Court of Appeals for the Eleventh Circuit issued a decision that threatens significant consequences for a variety of loan servicing and debt collection industries. The upshot of the court’s holding...more
4/22/2021
/ Appeals ,
Article III ,
Corporate Counsel ,
Debt Collection ,
Debt Collectors ,
Debtors ,
FDCPA ,
Loan Servicing ,
Motion to Dismiss ,
Standing ,
Third-Party
Yesterday, the CFPB issued a proposed rule that would extend implementation of both parts of its debt collection rule by 60 days — from November 30, 2021, to January 29, 2022. The debt collection rule, which we have discussed...more
On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) published its debt collection final rule in the Federal Register. This is obviously a significant event because the rule is set to become effective one...more
On Thursday, July 2, the Consumer Financial Protection Bureau (CFPB) announced that it plans to publish final debt collection rules in October 2020. The final rules will be the first rules clarifying the nearly 40-year-old...more
The Consumer Financial Protection Bureau (CFPB) formally extended the comment period for its proposed debt collection rulemaking on Friday, August 2. Rather than requiring that all comments be submitted by August 19, 2019,...more
Last November, Bradley’s Financial Services Perspectives team predicted that the Consumer Financial Protection Bureau’s (CFPB) then upcoming Notice of Proposed Rulemaking (NPRM) for the Does the New Debt Collection Rule Apply...more
6/14/2019
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Creditors ,
Debt Collection ,
Debt Collectors ,
Dodd-Frank ,
Enforcement ,
Enforcement Authority ,
FDCPA ,
NPRM ,
Proposed Rules ,
UDAAP
The Consumer Financial Protection Bureau (CFPB) previously indicated in its Fall 2018 Rulemaking Agenda that it intends to issue a Notice of Proposed Rulemaking (NPRM) in the Spring of 2019 regarding debt-collection practices...more
On October 17, 2018, the Bureau of Consumer Financial Protection (BCFP), formerly known as the CFPB, announced that it plans to issue a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA)...more
Earlier this week, the Bureau of Consumer Financial Protection (BCFP) released a 50-State Complaint Snapshot. Credit reporting, debt collection, and mortgage continued to be the top three categories of complaints both...more
On October 17, 2018, the Bureau of Consumer Financial Protection (BCFP), formerly known as the CFPB, announced that it plans to issue a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA)...more
Security Group, Inc. and several of its wholly owned subsidiaries entered into a consent order with the Consumer Financial Protection Bureau (CFPB) in which it agreed to injunctive relief and to pay a $5 million penalty....more
6/21/2018
/ Civil Monetary Penalty ,
Consent Order ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Enforcement Actions ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Injunctive Relief ,
UDAAP ,
Unfair or Deceptive Trade Practices
On Friday, the Consumer Financial Protection Bureau (CFPB) published a request for information about the credit card market. The CFPB uses responses to those requests, in conjunction with other data and research, to publish...more
3/14/2017
/ Banking Sector ,
CARD Act ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Creditors ,
Debt Collection ,
Deferred Interest Products ,
Financial Services Industry ,
Innovation ,
Online Marketplace Lending ,
Request For Information ,
Rewards Programs ,
UDAAP
The Consumer Financial Protection Bureau (CFPB) announced a consent order with Navy Federal Credit Union (Navy Federal) on October 11, 2016. While financial institutions should always analyze CFPB consent orders closely and...more
10/18/2016
/ Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Unions ,
Creditors ,
Debt Collection ,
Debtors ,
Electronic Account Restrictions ,
Enforcement Actions ,
FDCPA ,
Financial Institutions ,
U.S. Navy ,
UDAAP
Last week , the Consumer Financial Protection Bureau (CFPB) met with the Community Bank Advisory Council (CBAC) to discuss the CFPB’s July 28, 2016, outline of the proposed debt collection rules (Outline) intended to...more
As noted previously, the Consumer Financial Protection Bureau (CFPB) published an outline on July 28, 2016, of proposed debt collection rules intended to “drastically overhaul the debt collection market.” Earlier this week,...more
The Consumer Financial Protection Bureau (CFPB) published an outline on July 28, 2016, of proposed debt collection rules intended to “drastically overhaul the debt collection market.” Pursuant to the Small Business Regulatory...more
The Consumer Financial Protection Bureau (CFPB) issued its long-awaited proposals for addressing its concerns in the debt collection industry yesterday. CFPB Director Richard Cordray acknowledged that the entity’s proposals...more