Military Issues

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Servicemembers are the subject of heightened legal protections.  In this week’s podcast, we discuss the CFPB’s annual report on servicemember complaints issued at the end of last month.  We look at the products that received the most complaints from servicemembers, the specific issues complained about, and the litigation and regulatory risks to consumer financial service…

The CFPB’s Office of Servicemember Affairs has released its annual report on complaints submitted to the Bureau by servicemembers.

The report covers the period April 1, 2017 through August 31, 2018.  During that period, the Bureau received approximately 48,800 complaints from servicemembers, with credit reporting, debt collection, and mortgages, respectively, the first, second, and third…

The CFPB announced yesterday that it has transmitted a proposal to Congress that would give it clear authority to conduct supervisory examinations for compliance with the Military Lending Act (MLA).

Last summer, former CFPB Acting Director Mulvaney reportedly announced that he planned to end routine examinations for MLA compliance because the Dodd-Frank Act did not…

At the end of last week, the Federal Trade Commission (FTC) and the Department of Veterans Affairs (VA) announced that they have entered into a Memorandum of Agreement (MOA) “to provide mutual assistance in the oversight and enforcement of laws pertaining to the advertising, sales, and enrollment practices of institutions of higher learning and other…

Twenty-three Democratic members of the House Financial Services Committee have sent a letter to Kathy Kraninger, the CFPB’s new Director, urging the Bureau to resume examining its supervised entities for compliance with the Military Lending Act (MLA).  The Democrats signing the letter include Maxine Waters, currently the Ranking Member, who is expected to become Committee…

In this week’s episode, we discuss recent state legislative and enforcement developments involving state analogues to the federal Servicemembers Civil Relief Act.  We review state efforts to increase the duration of federal protections, expand the groups entitled to them, and extend similar protections to additional products and services.

To listen and subscribe to the podcast,…

In this week’s episode, we discuss recent enforcement activity under the Military Lending Act and the Servicemembers Civil Relief Act, as well as takeaways about compliance.  We also review the CFPB’s controversial decision to no longer conduct exams for MLA compliance, look at the legal basis for the decision, and analyze the arguments made by…

The Department of Justice recently entered into a settlement with Hudson Valley Federal Credit Union to resolve allegations that it violated the Servicemembers Civil Relief Act (SCRA) by repossessing vehicles owned by servicemembers without first obtaining the required court orders.  The settlement agreement  requires Hudson Valley to pay $65,000 to compensate seven servicemembers whose vehicles…

The New York Attorney General has filed a lawsuit against a group of commonly owned and managed companies headquartered in New York that include companies operating retail jewelry stores in numerous states under the name Harris Jewelry and another company providing financing for sales made at such stores under the name Consumer Adjustment Corp.  One…