Last night, the Consumer Financial Protection Bureau (CFPB) released its Larger Non-Bank Participant Rule. The Rule is available here. In addition to releasing the Rule, the CFPB released an examination manual and a fact sheet. Some highlights: The Rule is effective January 2, 2013 — 70 days from today. The Rule provides a description of the examination process. It does not apply to entities that originate credit. A person is subject to the Rule if they have more than $10 million in “annual receipts” resulting from consumer debt collection. “Annual receipts” is derived from a three-year average of receipts. “Annual receipts” does not include “those receipts that…
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Consumer Financial Protection Bureau
As Fall brings a chill to early morning weather, a string of federal agency enforcement actions are supplying a lot of unwanted heat for the consumer financial services industry. Today, the Federal Trade Commission announced that it has entered into a Consent Order with Equifax Information Services LLC, over charges that it had allegedly improperly sold lists of consumers who were late on their mortgage payments. The Consent Order requires Equifax to pay nearly $393,000 to the FTC. In a separate action, an Equifax customer will pay the FTC civil penalties of $1.2 million under a Consent Order concerning its alleged use of the same lists…
As reported today in the Consumer Law and Policy Blog, University of Utah Law Professor Christopher L. Peterson joined the Consumer Financial Protection Bureau as a Senior Counsel for Enforcement Strategy. Although Professor Peterson and I do not see eye to eye on many issues, over the past decade his scholarly works have impacted consumer financial services law. If you ever have the opportunity to hear Chris speak on consumer financial services law, do so. You might not like what you hear, but he knows how to make his point in a way that captures your attention.
Yesterday the Consumer Financial Protection Bureau (“CFPB”) released its proposed rule “Defining Larger Participants in Certain Consumer Financial Product and Service Market.” The proposed rule calls for the CFPB to regulate certain attorneys to protect the public welfare. Why? Becuase, Collection attorneys and law firms may collect through litigation (i.e., filing suit against consumers to collect debt). How dare those attorneys file complaints and litigate lawsuits. You can bet I’ll have a little more on the topic in a few days.
On Day Two of the Consumer Financial Protection Bureau (“CFPB”), it unveiled its online Credit Card Complaint form. It is available here: http://tinyurl.com/3o9p8pr. Enter a complaint and the CFPB says “We’ll forward your issue to your credit card company, give you a tracking number, and keep you updated on the status of your complaint.” In keeping with the unique look of the CFPB’s website, the form is neat, sleek and real simple, but there’s a problem – credit card holders may lose important rights when deciding to use the CFPB’s portal as their only form of making disputes. Credit card…