A&B ABstract On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help them prepare for state cybersecurity examinations and, ultimately, improve cybersecurity maturity and protect financial institution infrastructure. These tools are designed to address key aspects of the Uniform Rating System for Information […]
Federal Trade Commission (FTC)
Joint Trade Associations Reject the CFPB’s “Discrimination-Unfairness” Theory
In a June 28 letter to Director Chopra and accompanying White Paper and press release, the ABA, CBA, ICBA, and the U.S. Chamber of Commerce have called on the Consumer Financial Protection Bureau (CFPB or Bureau) to rescind recent revisions made to its UDAAP examination manual that had effectuated the CFPB’s controversial theory that alleged […]
The Hunstein Case: Upending Servicing and Debt Collection?
A&B Abstract: The U.S. Court of Appeals for the Eleventh Circuit, covering Alabama, Florida, and Georgia, recently decided in Hunstein v. Preferred Collection and Management, Inc., that a debt collector’s communication with its third-party vendor violated section 1692c(b) of the Fair Debt Collection Practices Act (“FDCPA”), which prohibits a debt collector for communicating, in connection […]
What Do the CFPB’s and FTC’s 2020 Debt Collection Activity Forecast for 2021?
On March 22, 2021, the Consumer Financial Protection Bureau (CFPB) released its 2020 annual report to Congress on the administration of the Fair Debt Collection Practices Act (FDCPA). The CFPB’s annual report follows the Federal Trade Commission’s (FTC) annual letter to the CFPB regarding the FDCPA, publicly released on March 19, 2021. The annual report highlights both agencies’ efforts […]
FTC Seeks Comment on Proposed Changes to FCRA Rules for Motor Vehicle Dealers
A&B ABstract: The FTC is seeking public comment on proposed changes to five FCRA rules aimed at clarifying that these rules, as promulgated by the FTC, apply only to motor vehicle dealers, as equivalent rules promulgated by the CFPB will apply to other entities. The Federal Trade Commission (“FTC”) has announced it is seeking […]