Michael Cumming

Morgan Lewis

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Latest Posts › Debt Collection

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CFPB Issues Final (and First Ever) Debt Collection Rule

The Consumer Financial Protection Bureau (Bureau or CFPB) on October 30 issued the first part of its long-awaited debt collection final rule, which restates and clarifies prohibitions on harassment and abuse, false or...more

11/9/2020 / Consumer Financial Protection Bureau (CFPB) , Debt Collection , FDCPA , Final Rules , Financial Regulatory Reform , Financial Services Industry , Regulatory Requirements , Rulemaking Process , Unfair or Deceptive Trade Practices

OCC Madden Rule Is First Step Toward Needed Clarity for Banks Fintechs and Nonbank Lenders

The Office of the Comptroller of the Currency (OCC) issued a final rule on May 29 clarifying that when a national bank or national savings association sells, assigns, or otherwise transfers a loan, interest permissible before...more

6/5/2020 / Consumer Financial Products , Debt Collection , Financial Services Industry , FinTech , Interest Rates , Madden v Midland Funding , National Bank Act , Non-Bank Lenders , OCC , True Lender

CFPB Proposes New Debt-Collection Regulations

The Consumer Financial Protection Bureau (CFPB, the Bureau) issued a Notice of Proposed Rulemaking (the Proposal) to establish implementing regulations for the Fair Debt Collection Practices Act (FDCPA). Although it has been...more

5/8/2019 / Consumer Financial Protection Bureau (CFPB) , Debt Collection , FDCPA , Financial Services Industry , Investment Management , NPRM

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