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If you are reading this article, you are likely aware that a creditor collecting its own debts in its own name is not a "debt collector" under the federal Fair Debt Collection Practices Act ("FDCPA") or its implementing rule,...more
The U.S. Department of Justice (DOJ) and state authorities have agreed to a consent order with a large national bank to resolve allegations that the bank engaged in a pattern or practice of lending discrimination by affecting...more
A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more
The Office of the Comptroller of the Currency (OCC) has issued a bulletin (2023-37) that provides guidance on managing risks associated with “buy now, pay later” (BNPL) lending. The BNPL loans addressed in the bulletin are...more
In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more
Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more