Back to Basics, Continued—Starting off the New Year with the CFPB January 4, 2023 United States: Two years ago, our blog discussed the appointment of Rohit Chopra to lead the CFPB. See Back to Basics, Continued—it’s Time to Talk About the CFBP Again. Chopra had let it be known that his top priorities for the Bureau would include ramping up enforcement of the fair lending laws and expanding the definition of “Unfair, Deceptive or Abusive Acts or Practices.”
Back to Basics, To Be Continued… December 28, 2022 United States: We hope that you have found our Back to Basics blog series to be helpful this past year.
Back to Basics, Continued—The Servicemembers Civil Relief Act and the CFPB December 21, 2022 United States: I write often about the Servicemembers Civil Relief Act (SCRA). It should come as no surprise to consumer finance companies 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—Indirect Lending, a/k/a Taking Assignment of Consumer Credit Contracts from Credit Sellers December 14, 2022 United States: I have written in the past about indirect lending. See Back to Basics, Continued - Let’s Talk About Purchasing and Taking Assignment of Retail Installment Sales Contracts and my more recent post Back to Basics, Continued—Determination and Computation of the Maximum Allowable Finance Charge. But, it has been some time since I discussed the importance of the master agreement between the credit seller and the assignee finance company.
Back to Basics, Continued—“Buy now, Pay later” again December 7, 2022 United States: I wrote about the Buy Now, Pay Later (BNPL) approach to selling and purchasing consumer goods at the beginning of this year. See Back to Basics, Continued—What Does “Buy Now, Pay Later” Mean for Consumer Finance? The trend to BNPL during this holiday season has skyrocketed.
Back to Basics, Continued—Furnishers Obligation to Investigate Consumer Disputes November 30, 2022 United States: I have written many times about the obligations that creditors have to investigate complaints by consumers that information included in their credit reports to credit bureaus (CRAs) is inaccurate.
Back to Basics, Continued—Payday Loan v. Earned Wage Access Program November 23, 2022 United States: What is the difference between a Payday Loan and an Earned Wage Access Program? I thought you might want to know.
Back to Basics, Continued—Let’s Talk About Language Placement (Part III)—the Check-in-the Mail November 16, 2022 United States: Two weeks ago, I addressed language placement in a consumer credit contract concerning reporting missed payments, late payment or other defaults to credit bureaus required by the Fair Credit Reporting Act (FCRA). See Back to Basics Continued—Let’s Talk About Language Placement—Negative Information Reporting Under the Fair Credit Reporting Act.
Back to Basics, Continued—Let’s Talk About Language Placement (Part II)—the Credit Application November 9, 2022 United States: I addressed the issue of required language in a consumer contract under the Fair Credit Reporting Act last week. This week I want to talk about required language in the Credit Application.
Back to Basics Continued—Let’s Talk About Language Placement—Negative Information Reporting Under the Fair Credit Reporting Act November 2, 2022 United States: Other than Truth-in-Lending, probably the most important consumer credit statute to know well is the Fair Credit Reporting Act (FCRA). Originally the FCRA was designed to rein-in the most troubling practices of credit reporting agencies (CRAs), with only incidental requirements placed upon credit grantors.