Back to Basics, Continued—Equal Credit Opportunity Again! July 1, 2020 United States: The requirements of the Equal Credit Opportunity Act (ECOA) and its enforcing Regulation B are pretty well known. After all, the ECOA is one of the original chapters of the Consumer Credit Protection Act, dating back to the 1960s.
Back to Basics, Continued—Revising the Contract When the Servicemember Invokes Protection Under the Servicemembers Civil Relief Act (SCRA) June 24, 2020 United States: For those who have been paying attention, it comes as no surprise that men and women joining the armed forces have the right to an adjustment of an interest rate so as not to exceed 6% on a financial obligation incurred prior to military service.
Back to Basics, Continued - Electronic Signatures June 17, 2020 United States: I wrote a blog about doing business electronically last year. See the blog here. I want to revisit this issue with you because of the COVID-19 Pandemic, and the impact it is having on obtaining “wet” signatures on promissory notes and contracts.
Back to Basics, Continued—Is a Charge Assessed to the Consumer for Use of a Debit Card a Finance Charge? June 10, 2020 United States: In August of 2018, I published a Back to Basics blog in the form of a test or challenge. I named 13 fees and challenged you to respond as to whether each was or was not a finance charge.
Back to Basics, Continued - Direct Dispute Complaints v. e-OSCAR Referred Complaints June 3, 2020 United States: I’ve written in the past about Frivolous or Irrelevant Disputes and the obligations of finance companies under the Fair Credit Reporting Act’s Furnisher Rule.
Back to Basics, Continued—Consumer Complaints May 27, 2020 United States: In April, the CFPB received a record number of complaints about lenders—42,774 to be exact. According to CFPB Director Kraninger, the Bureau received more complaints from consumers in April than in any month since the Bureau first began to take complaints in December of 2011.
Back to Basics, Continued—Rethinking the Value of Credit Insurance Products May 20, 2020 United States: Credit sellers and lenders are continually challenged about the value of credit insurance that may be offered to consumers as part of a sale or loan transaction.
Back to Basics, Continued - The Value of Consumer Finance May 13, 2020 United States: One of my early blogs addressed the value of consumer finance in the day-to-day lives of Americans. I wrote about the unique place that finance companies have in the loan world and how consumer finance companies make personal loans for everyday wants and needs.
Back to Basics, Continued - Whatever Happened to the Small Dollar Loan Rule and the Leveraged Payment Mechanism? May 6, 2020 United States: Remember 2017? Seems a long time ago. In the waning days of 2017, the Consumer Financial Protection Bureau (CFPB) issued its final rule on Small Dollar Lending—the Payday, Vehicle Title, and Certain High-Cost Installment Loans Final Rule.
Back to Basics, Continued—Let’s Be Very Careful What We Say! April 29, 2020 United States: While I don’t think about this often, the fact is that many consumer finance company lenders and credit sellers are themselves commercial borrowers. Even our largest companies borrow money from banks and other commercial lenders for capital needs as well as basic operations. So, what? Why raise this matter in a Back to Basics blog?