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Posts published in “Compliance Management”

CFPB Calls For Greater Data Integrity in Debt Collection

Recent remarks from Consumer Financial Protection Bureau Deputy Director Steven Antonakes indicate that the CFPB remains particularly interested in data integrity during debt collection. Speaking at the National Community Reinvestment Coalition Annual Conference in Washington yesterday, Antonakes said the bureau is “concerned that the accuracy of account information degrades as it…

Lawyer and Non-Lawyer Supervision — A Lesson in Avoiding an Ethical Transgression

For several years my attorney ethics presentations and papers have emphasized that lawyer supervision and particularly non-lawyer supervision, in my experience, is an area of concern for attorneys who practice debt collection law. A recent opinion from New York’s Appellate Division, Second Department, concerning the conduct…

CFPB Provides Dispute Guidance to FCRA Furnishers on Enhanced e-OSCAR

Changes to the systems by which banks and other entities (also known as “furnishers”)  supply credit reporting agencies with consumer credit information prompted a Bulletin yesterday from the Consumer Financial Protection Bureau emphasizing the greater role it sees documents playing in the consumer credit dispute process. In announcing…

Yes, the CFPB is Serious About Self-Reporting!

If your organization might have violated a consumer financial protection law, should it disclose that potential violation to the Consumer Financial Protection  Bureau? It seems that at least one CFPB insider believes that the potential violation should be self-reported. At today’s meeting of the Consumer Financial Services Committee…