On December 13, 2021, the Federal Trade Commission (FTC) announced that, under the terms of a settlement, a group of phantom debt collectors were permanently banned from the debt collection industry. The term “phantom debt”...more
On January 4, 2021, the Office of the Comptroller of the Currency (“OCC”) published an Interpretive Letter clarifying the authority of national banks and federal savings associations to participate in independent node...more
Earlier this month, the Consumer Financial Protection Bureau issued a consent order against a New Jersey debt buyer accused of threatening and suing consumers to collect debts in states where it did not have a legally...more
The CFPB issued Part II of its final collection rule on December 18, 2020. Part II supplements the final rule issued on October 30, 2020, about which our team published a series of blog posts on topics such as impacts on...more
Last week, the CFPB filed a lawsuit in a California federal district court against Performance SLC LLC, Performance Settlement, and Daniel Crenshaw, the owner and CEO of the two companies. Performance SLC is a...more
Among the items proposed in the CFPB’s NPRM that were adopted in its final collections rule are restrictions on call attempts and a limited content message definition. While many observers are somewhat dismayed that the...more
It appears that the final chapter of the ITT Educational Services, Inc. (“ITT”) story was written last week with the CFPB’s announcement that it entered into a stipulated settlement with PEAKS Trust 2009-1 (“PEAKS”), a...more
The Seventh Circuit held in Koehn v. Delta Outsource Group, Inc., et al. that using the term “current balance” in a collection letter to reference a static amount of debt was not misleading and did not violate the Fair Debt...more
The CFPB announced on August 14, 2019 that, subject to the approval of the Federal District Court for the Eastern District of Arkansas, the Bureau and the Arkansas Attorney General have entered into a proposed settlement with...more
9/3/2019
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