News & Analysis as of

Fair Debt Collection Practices Act Loan Servicing

Goodwin

CFPB Permanently Bans Large Student Loan Servicer from Market and Orders Redress of $120 Million

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On September 12, 2024, the CFPB announced that it entered into a stipulated proposed order with a large student loan servicer resolving allegations that the servicer forced borrowers into costly repayment options.​ Under the...more

Hudson Cook, LLP

CFPB Bites of the Month - 2023 Annual Review - Debt Collection

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In this article, we share a timeline of our monthly "bites" for 2023 applicable to debt collection. If debt collection in 2023 had a theme it would be medical debt....more

Cooley LLP

CFPB Publishes Spring 2022 Supervisory Highlights

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On May 2, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) published its spring 2022 Supervisory Highlights report. As discussed in more detail below, the report addresses observations made in examinations...more

Locke Lord LLP

An Inconvenient Decision on ‎Convenience Fees

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Last month, the Fourth Circuit Court of Appeals rendered a decision regarding convenience fees in Alexander v. Carrington Mortgage Services, LLC, 23 F.4th 370 (4th Cir. 2022), which potentially spells trouble for loan...more

Bradley Arant Boult Cummings LLP

New Federal Appellate FDCPA Decision Threatens to Upend Debt Collection and Loan Servicing

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

BCLP

Recent Decisions Support the Legality of “Pay-to-Pay” Fees in Florida

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Many mortgage servicers allow borrowers to make loan payments over the telephone, and the servicers charge a small convenience fee for this special service. These telephone convenience fees, or “pay-to-pay” fees as coined by...more

Alston & Bird

District Courts Split on Convenience Fees Under Debt Collection Laws

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A&B ABstract: In a number of recent decisions, district courts have split on the issue of whether a mortgage servicer violates the Fair Debt Collection Practices Act (“FDCPA”) and related state debt collection statutes by...more

Carlton Fields

Real Property, Financial Services, & Title Insurance Update: Week Ending August 7, 2020

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Real Property Update - Affirmative Defense / Waiver: Homeowner unable to raise statute of limitations affirmative defense for the first time in motion for summary judgment – Deer Brooke S. Homeowners Ass’n of Polk Cty.,...more

Goodwin

CFPB Publishes its Winter 2020 Supervisory Highlights

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On February 14, 2020, the Consumer Financial Protection Bureau (CFPB) released its Winter 2020 Supervisory Highlights (Report). It summarizes the CFPB’s findings on violations in the areas of debt collection, mortgage...more

Ballard Spahr LLP

CFPB Winter 2020 Supervisory Highlights looks at debt collection, mortgage servicing, payday lending, student loan servicing

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The CFPB has released the Winter 2020 edition of its Supervisory Highlights.  The report discusses the Bureau’s examinations findings in the areas of debt collection, mortgage servicing, payday lending, and student loan...more

Hinshaw & Culbertson LLP

Does the FDCPA Apply to Debt Buyers? U.S. Supreme Court Will Soon Decide

On April 18, 2017, the Supreme Court of the United States heard oral argument on the issue of whether the Fair Debt Collection Practices Act ("FDCPA") extends beyond traditional "debt collectors" to those entities that...more

Goodwin

Supreme Court Hears Oral Argument on Scope of FDCPA

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On April 18, 2017, the United States Supreme Court, once again with nine justices sitting on the bench, heard oral arguments in Henson v. Santander Consumer USA, Inc., No. 16-349, concerning the scope of the Federal Debt...more

Bradley Arant Boult Cummings LLP

CFPB and Two States File Suit Against Student Loan Company Navient

The CFPB announced on Wednesday that it had filed a lawsuit against Navient Corporation, formerly part of Sallie Mae, and two of its subsidiaries for alleged “systematic” failures in student loan servicing. The complaint...more

Dechert LLP

CFPB Outlines New Proposals For Third Party Consumer Debt Collection

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The Consumer Financial Protection Bureau (CFPB) in the U.S. published an outline of proposals on July 28, 2016 to govern consumer debt collection by debt collectors including third-party collection agencies, debt buyers,...more

Goodwin

Servicers Beware: RESPA Transfer of Servicing Letter May Trigger FDCPA Initial Debtor Communication Disclosure Requirement

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In Hart v. FCI Lender Services, Inc., the Second Circuit made it clear that servicers should pay close attention to initial communications with borrowers upon commencing loan servicing when it determined in an August 12, 2015...more

Blank Rome LLP

Third Circuit Clarifies FDCPA Restrictions on Third-Party Communications

Blank Rome LLP on

Action Item: Lenders and servicers should continue to maintain policies and procedures that minimize third-party communications and ensure maintenance of sufficient records documenting the frequency and purpose of those...more

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