As the federal regulator with supervisory authority over (non-Federal Reserve member) state banks and savings associations, the FDIC continues to play an important role in the consumer protection arena.  On June 30, 2020, at 3:00 p.m. ET, PLI will offer a one-hour briefing, “Consumer Protection: What’s Happening at the FDIC.”  Leonard Chanin, Deputy to the

The CFPB has issued a statement regarding its supervisory and enforcement practices in connection with the electronic provision of certain credit card disclosures during the pandemic that are required by Regulation Z to be provided in writing.

The Bureau discusses the use of E-Sign consent to provide disclosures electronically that pursuant to underlying law, such

We explore a wide range of topics with AG Weiser including: who are his key staff members and their backgrounds; his office’s actions in response to COVID-19; recent changes to the CO Consumer Protection Act; and his office’s activities concerning student loans, robocalls, payday lending, and data privacy and security and its approach to consumer

This Friday, June 5, from 12:00 p.m. to 1:00 p.m. ET, Ballard Spahr will hold a webinar, “State Attorney General Priorities: Coronavirus and Beyond.”  Our special guest speakers will be three representatives from state Attorney Generals’ offices: Bernard Eskandari from California, Tom James from Illinois, and Max Weinstein from Massachusetts.  Our guests will discuss their

To the dismay of consumers, banks, creditors, and debt collectors alike, there currently is uncertainty as to whether CARES Act stimulus payments to individuals and Paycheck Protection Program loan proceeds can be garnished by private creditors.  Ballard Spahr attorneys John Culhane and Lori Sommerfield have published an article, “Garnishment Must Be Clarified in Pandemic

In the aftermath of a statement from the CFPB and the four federal banking agencies encouraging small-dollar lending in response to the COVID-19 pandemic and guidance from the four federal banking agencies on “Interagency Lending Principles for Offering Responsible Small-Dollar Loans,” the CFPB has issued a “No-Action Letter (NAL) Template” for small-dollar loan

There is no question that a COVID-related recession will bring about a wave of regulatory enforcement activity and consumer litigation. But what areas will the regulators and plaintiffs’ counsel focus on, and how can the industry stay out of the crosshairs? On June 2, the Practicing Law Institute is hosting a free one-hour briefing that

The Federal Reserve, OCC, FDIC, and NCUA have issued “Interagency Lending Principles for Offering Responsible Small-Dollar Loans.”  The agencies state that the principles are intended “to encourage supervised banks, savings associations, and credit unions to offer responsible small-dollar loans to customers for consumer and small business purposes.”

The issuance of the guidance follows

We look at the impact of federal and state law including relevant CARES Act provisions, state garnishment directives, and federal preemption, identify issues banks should consider in handling garnishments or exercising setoff rights, and offer suggestions for mitigation measures banks can take as they decide how to address the challenges in this area.

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Comment period extension.  Yesterday, the CFPB announced a second 60-day extension of the comment period for its supplemental proposal that would require debt collectors to make specified disclosures when collecting time-barred debts.  The CFPB previously extended the initial May 4 comment deadline until June 5.  The new comment deadline is August 4, 2020.  The