It appears that the final chapter of the ITT Educational Services, Inc. (“ITT”) story was written last week with the CFPB’s announcement that it entered into a stipulated settlement with PEAKS Trust 2009-1 (“PEAKS”), a special purpose entity created in 2009 to purchase, own, and manage certain private student loans with students enrolled at ITT.… Continue Reading
unfair and abusive
House Financial Services Committee to hold Sept. 26 hearing on abusive debt collection practices
The House Financial Services Committee will hold a hearing entitled “Examining Legislation to Protect Consumers and Small Business Owners from Abusive Debt Collection Practices,” on Thursday, September 26, 2019, at 10:00 a.m. The hearing will also be live streamed.
The following witnesses are scheduled to testify:
- Rev. Dr. Cassandra Gould, Pastor, Quinn Chapel A.M.E.
Is Online Lead Generation Inherently Deceptive?
This post is the third in a series we’re writing on the FTC’s workshop on online lead generation entitled Follow the Lead. In our first post, we explored how online lead generation works. In our second, we covered the role that disclosures can and should play. Here, we will discuss the allegation the CFPB and certain consumer groups raise that the industry is “inherently deceptive.”… Continue Reading
Further comment on payday lending and deposit advances
As suggested by prior blog posts, I am no fan of the direction the CFPB, OCC and FDIC seem to be going with respect to payday and deposit advance loans. These agencies have all signaled a willingness to prohibit these loans without regard to Dodd-Frank’s definitions of the terms “unfair” and “abusive” and without applying the cost-benefit analysis required by the statutory language.… Continue Reading