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Financial Services Industry Third-Party Service Provider Consumer Financial Products

Ballard Spahr LLP

Regulators Outline Risks that Third-Party Servicers Pose to Banks

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Banking regulators have issued a joint statement outlining the potential risks that financial institutions face in arrangements with third parties to deliver bank deposit products and services and examples of risk management...more

Ballard Spahr LLP

FHA Seeks Comment on Third Party Originator Fraud With Short Comment Timeframe

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On June 17, 2024, FHA announced in draft Mortgage Letter 2024-12 a proposed revision to its Defect Taxonomy to clarify that fraud or material misrepresentation involving a sponsored Third-Party Originator (TPO) is a Tier 1...more

Goodwin

California Department of Financial Protection Issues Consent Order Against Fintech Company

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​​​​​​​On January 9, 2024, the California Department of Financial Protection and Innovation (DFPI) announced that it entered into a consent order with a Delaware fintech company that provided California consumers with access...more

Orrick, Herrington & Sutcliffe LLP

Bowman discusses bank and third-party cyber risk management expectations

On February 15, Federal Reserve Board Governor Michelle W. Bowman delivered remarks at the Midwest Cyber Workshop, during which she discussed topics related to third-party service provider reliance and regulatory expectations...more

Sheppard Mullin Richter & Hampton LLP

CFPB’s New Interpretive Rule Sets Sights on Digital Marketing Vendors

On August 10, the CFPB issued an interpretive rule stating that digital marketing providers that are involved in the identification or selection of prospective customers or the selection or placement of content to affect...more

Manatt, Phelps & Phillips, LLP

Beyond Big Tech: CFPB’s Payments Data Obsession May Broadly Target Third-Party Data Purchasers

In late October, the Consumer Financial Protection Bureau (CFPB) sent a shot across the bow at Big Tech’s use of consumer payments data. While much of the industry has focused on the impact on Big Tech, some lenders, lead...more

Ballard Spahr LLP

Google updates financial products and services policy to restrict advertising of debt relief services

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Google has updated its financial products and services policy to restrict the advertisement of debt settlement, debt management services, and credit repair services....more

Ballard Spahr LLP

CFPB issues report on tradeline reporting by third-party debt collectors

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The CFPB has issued a new report on tradelines reported by third-party debt collectors as reflected on credit reports compiled by nationwide consumer reporting agencies.  The third-party collector tradelines consist of those...more

Ballard Spahr LLP

Texas amends debt collection law to add new requirements for debt buyers

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On June 14, 2019, Texas Governor Greg Abbott signed HB 996, which amends Chapter 392 of the Texas Finance Code dealing with debt collection.  The amendments are effective September 1, 2019. ...more

Polsinelli

The CFPB’s Long Awaited Debt Collection Rule is Certain to Shake Up the Industry

Polsinelli on

On May 7, 2019, the Consumer Financial Protection Bureau (CFPB) issued a Notice of Proposed Rulemaking (the Proposed Rulemaking) to implement portions of the Fair Debt Collection Practices Act (FDCPA)....more

Ballard Spahr LLP

CFPB to hold Town Hall in Philadelphia

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The CFPB has announced that it will hold a Town Hall to take place in Philadelphia, Pennsylvania beginning at Noon on May 8, 2019....more

Ballard Spahr LLP

Student Loan Advocacy Group Pushes Department of Education to Increase Oversight of For-Profit Colleges and Contractors

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The Student Borrower Protection Center (SBPC)—an organization established by former CFPB Student Loan Ombudsman Seth Frotman—recently published an article examining the Department of Education’s oversight of “lead...more

Troutman Pepper

Wells Fargo Consent Orders Highlight Importance of Acting on Information From Third-Party Vendors

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The OCC and CFPB consent orders issued against Wells Fargo on April 20 cited deficiencies in third-party oversight practices. The orders are the latest additions to an ever-expanding body of agency enforcement actions...more

Ballard Spahr LLP

OCC issues risk management principles for new activities

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On October 20, 2017, the Office of the Comptroller of the Currency (OCC) issued Bulletin 2017-43 (the “Bulletin”) outlining principles that OCC-supervised banks should follow to prudently manage the risks associated with...more

Bradley Arant Boult Cummings LLP

CFPB’s Debt Collection Rules May Be Coming Sooner Than Some in the Industry Anticipated

Last week, at the Consumer Advisory Board Meeting in Washington D.C., Consumer Financial Protection Bureau (CFPB) Director Richard Cordray provided an update on one of the most highly anticipated areas in the debt collection...more

Smith Debnam Narron Drake Saintsing & Myers,...

Fourth Circuit Weighs in on Article III Standing

The Fourth Circuit recently examined the issue of Article III standing in the context of the FDCPA. In Ben-Davies v. Blibaum & Associates, P.A., 2017 U.S. App. LEXIS 9667 (4th Cir. June 1, 2017), the consumer sought to...more

Pierce Atwood LLP

Trying Times for Secondary Market for Consumer Debts

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Those engaged in the business of selling consumer debt or of purchasing delinquent consumer debt for collection purposes are well-advised to take heed of the recent developments on the judicial and legislative fronts that...more

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