The CFPB has filed a lawsuit in a California federal district court against Credit Repair Cloud (CRC), a software company, and its owner, in which the Bureau alleges that the defendants provided substantial assistance to credit-repair businesses charging unlawful advance fees in violation of the Telemarketing Sales Rule (TSR) and the Consumer Financial Protection Act (CFPA). … Continue Reading
service provider
CFPB amends service provider guidance
The CFPB has reissued its guidance on service providers which was formerly titled CFPB Bulletin 2012-03, and as published in the Federal Register on October 26, 2016, is now titled “Compliance Bulletin and Policy Guidance 2016-02.”
The reissued guidance includes an amendment that the CFPB described as “needed to clarify that supervised entities have flexibility [in their risk management program for service providers] and to allow appropriate risk management.” … Continue Reading
Atlanta federal district court interprets CFPA standard for “substantial assistance” liability
Earlier this year, the CFPB filed a complaint in Atlanta federal district court targeting an alleged debt collection scam in which not only were the debt collectors named as defendants (Debt Collectors) but three companies involved in providing payment processing services to the Debt Collectors were also named as defendants. One of those companies processed payments for the debt collectors and the other two companies were independent sales organizations (ISO) that marketed the processor’s services to merchants and were responsible for screening and underwriting merchants.… Continue Reading
Online advertising and the CFPB
Nathan Newman, from an organization called Tech Progress, posted recently on Huffington Post calling for the CFPB to regulate online advertising. I spend a lot of time working on financial services online advertising issues, so this caught my eye (and also because it was highlighted in yesterday’s Consumer Bankers Association’s SmartBrief).… Continue Reading