Back to Basics, Continued - Consumer Protection in the Year 2020 September 9, 2020 United States: I am once again teaching Consumer Protection at the University of Alabama School of Law as an adjunct professor.
Back to Basics, Continued - A Primer on Ancillary Products September 2, 2020 United States: I recently wrote about the value of credit insurance products. See here. But, a fuller explanation may be called for.
Back to Basics, Continued—So Just Who Is a “Creditor” Anyway? August 26, 2020 United States: Until the other day, I thought there was no misunderstanding of the term “creditor.” After all, that term pervades consumer finance transactions and the governing laws and regulations. And, I thought that its meaning was well understood. However, I have learned that there is some confusion out there that bears explanation.
Back to Basics, Continued - The Significance of Using Sample Forms August 19, 2020 United States: Beginning several years ago, federal regulators accelerated the trend to offer sample forms as appendices to their regulations; and, they offered a “safe harbor” for use of such forms.
BACK TO BASICS, Continued—An Ounce of Prevention August 12, 2020 United States: There has been a rhythm to my Back To Basics blogs over the last two years. I started the effort with the expectation that I would remind readers of the impact on the day-to-day business operations of the various federal consumer laws, rules, and regulations. Starting with the Truth-in-Lending Act and going through the Dodd-Frank Wall Street Reform and Consumer Protection Act has given me a wealth of material to share with you.
Back to Basics, Continued—so, Just How Do I Comply With the New CFPB Small Dollar Loan Rule if I Offer My Customers the Ability to Schedule Recurring Payments? August 5, 2020 United States: In my recent blog here, I mentioned that my focus has been on avoiding becoming subject to the new CFPB Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (“Rule”), by staying away from the use of “leveraged payment mechanisms.”
Back to Basics, Continued - Is there a Bright Light Shining Through the Pandemic Tunnel? July 29, 2020 United States: The conventional wisdom about doing business during the Pandemic has been that we are lucky if we don’t have to close our doors.
Back to Basics, Continued - Who Wants to Talk About Small Dollar Lending Again? July 22, 2020 United States: This blog is titled “Back to Basics” for a reason. It is designed as a discussion of the everyday, important laws, regulations, policies and practices that directly impact installment lenders and credit sellers.
Back to Basics, Continued—Data Breach Notification July 15, 2020 United States: The CFPB has issued regulatory standards that are binding on creditors to help ensure the confidentiality of nonpublic personal information that is obtained as part of the credit extension process.
Back to Basics, Continued - Safeguarding Consumer Information, Again July 8, 2020 United States: I frequently write about a creditor’s duty to safeguard customer information. See for example, here and here.