In this podcast, we discuss in detail certain provisions of the CFPB’s Proposed Debt Collection Rule that create the possibility of a collector providing disclosures to consumers by means of electronic communications. Among other things, we detail the scope, requirements and limitations related to such electronic communications, review the logistical challenges the Rule poses as

On August 14, 2019, Senate Banking Committee Ranking Member Sherrod Brown (D-Ohio) wrote a letter imploring Consumer Financial Protection Bureau Director Kathy Kraninger to implement the payments provisions of the 2017 Payday Rule by the scheduled August 19, 2019, compliance date, by requesting a lifting of the stay imposed by the Texas federal district court

The Texas federal district court hearing the lawsuit filed by two trade groups challenging the CFPB’s final payday/auto title/high-rate installment loan rule (Payday Rule) entered an order on August 6 that once again continues the stay of the lawsuit and the August 19, 2019 compliance date for both the Payday Rule’s ability-to-repay (ATR) provisions and

In this podcast, we look at the unique challenges that the CFPB’s proposal may create for student loans.  Our discussion focuses on how the proposal’s call attempt limits, time/place limits for calls, texts, and e-mails, and special restrictions that apply to the aggregation of multiple student loans could impact communications with borrowers.

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The CFPB and the two industry trade groups that filed a lawsuit in a Texas federal district court challenging the CFPB’s final payday/auto title/high-rate installment loan rule (Payday Rule) filed a new status report with the court on August 2.

The status report references the CFPB’s proposal to revise the Payday Rule to rescind the

In a notice to be published in tomorrow’s Federal Register, the CFPB is extending the comment deadline for its proposed debt collection rules until September 18.  The proposal’s initial 90-day comment period was set to expire on August 19.

The Bureau states in the notice that it received two written requests from consumer advocates

In this podcast, we focus on provisions of the proposed rules that are of particular interest to the mortgage industry.  In addition to the special consumer definition, we look at the alternative content allowed in the validation notice and issues raised by the need to include the amount of the debt.  We also highlight areas

The CFPB recently issued an advance notice of proposed rulemaking (ANPR) requesting comments on how to revise the qualified mortgage (QM) provisions of the Regulation Z ability to repay rule in view of the impending expiration of the temporary QM for loans that meet the statutory QM criteria and are eligible for purchase or guaranty

In this podcast, we review what’s in the proposed limits and examine the challenges they present for collectors, including the retroactive lookback for call attempts and successful contacts, the treatment of ringless calls, calls placed at the consumer’s request, and the impact of call blocking technology.  We also discuss the implications for first party collections