In a recent consent order with a legal collection law firm, the Massachusetts Attorney General imposed significant restrictions on legal collection that go beyond previous CFPB consent orders, which we covered here. We believe that the Massachusetts Attorney General is likely to view at least some of the injunctive provisions in this consent order as setting standards for legal collections in Massachusetts generally, although it is possible that some provisions are unique to this particular case.… Continue Reading
Ballard Spahr to conduct webinar on March 24, 2016 entitled “CFPB Regulatory Certainty or Uncertainty? Consent Orders, Informal Guidance, and the New No-Action Letter Policy” Register here
The CFPB has issued a final policy statement on issuing “no-action” letters (NAL) for innovative financial products or services. The CFPB’s statement that the final policy was released on its website on February 18, 2016 presumably means that the final policy became effective immediately.… Continue Reading
Last December, the CFPB sued a Texas-based company, Union Workers Credit Services, alleging that the company deceived consumers into paying fees to sign up for a “platinum card” that purported to be a general-use credit card but, in actuality, could only be used to buy products from the company. See our prior post discussing the CFPB’s complaint here.… Continue Reading
The CFPB announced the settlement of enforcement actions brought in federal district court in Florida against four national mortgage insurers involving allegations that the insurers paid kickbacks to mortgage lenders in violation of Section 8 of the Real Estate Settlement Procedures Act.
The alleged kickbacks were paid through captive reinsurance arrangements in which the mortgage insurers, after insuring mortgage loans made by a lender, purchased reinsurance from the lender’s affiliate or subsidiary. … Continue Reading