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Today, the CFPB Announced that the Federal Financial Institutions Examination Council ("FFIEC") issued a new booklet in the FFIEC Information Technology Examination Handbook series, titled “Architecture, Infrastructure, and Operations.”  The CFPB noted that the booklet provides expanded guidance to help financial institution examiners assess the risk profile and adequacy of an entity’s information technology architecture, infrastructure, and operations.  Implied in… Read More

The CFPB issued an interim final rule that is effective May 3, 2021 to address certain debt collector conduct associated with an eviction moratorium issued by the CDC. The rule provides that debt collectors, as defined in the FDCPA, are required to provide written notice to certain consumers of their protections under the CDC Order’s eviction moratorium. Also, debt collectors… Read More

On January 15, 2021, the Consumer Finance Protection Bureau (CFPB) issued a small entity compliance guide summarizing the October 2020 debt collection rule. The small entity compliance guide is available here. Earlier, the October 2020 debt collection rule amended Regulation F to implement most of the Fair Debt Collection Practices Act’s (FDCPA), including, among other things, communications in connection with… Read More

In Paypal, Inc. v. Consumer Fin. Prot. Bureau, No. 19-3700 (RJL), 2020 U.S. Dist. LEXIS 244761 (D.D.C. Dec. 30, 2020), Judge Leon held that the CFPB’s Pre-Paid Card Rule exceeded the CFPB’s authority because Congress neither authorized it to require mandatory short forms nor permitted it to create a substantive restriction on a consumer's access to and use of credit under… Read More

On the heels of the October 2020 Debt Collection Final Rule issued by the Consumer Finance Protection Bureau (CFPB), on December 18, 2020, the CFPB issued an additional final rule implementing the Fair Debt Collection Practices Act. The December 2020 final rule and an executive summary are available here: https://www.consumerfinance.gov/compliance/compliance-resources/other-applicable-requirements/debt-collection/. The December 2020 final rule primarily addresses the (1) requirements… Read More

In Bureau of Consumer Fin. Prot. v. Fair Collections & Outsourcing, No. GJH-19-2817, 2020 U.S. Dist. LEXIS 223797, at *14-21 (D. Md. Nov. 30, 2020), Judge Hazel found constitutional ratification after SCOTUS' decision in Seila Law v. CFPB, 140 S.Ct. 2183 (2020). The Court next turns to a question left unanswered by Seila Law: whether the current CFPB Director properly… Read More

The CFPB has issued its Final Debt Collection rule:  https://www.consumerfinance.gov/policy-compliance/guidance/other-applicable-requirements/debt-collection/ The CFPB's Executive Summary is here:  https://files.consumerfinance.gov/f/documents/cfpb_october_2020_debt_collection_executive_summary.pdf We are reviewing the new Final Rule, and will be publishing period updates.  Stay tuned! Read More

In a recent weblog post, the CFPB warned against creditors undertaking unfair and discriminatory servicing of debts during the COVID-19 crisis.  The CFPB explained: We are monitoring the marketplace in real time and coordinating on an ongoing basis with fellow Federal and State regulators who are committed to stopping COVID-19-related malfeasance. We are taking, and will continue to take, swift… Read More

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