Stephanie is CEO of The iA Institute, a digital media company that specializes in providing insight and practical information to the complex debt industry. She has grown the company from its beginning as publisher of a daily newsletter (insideARM) to one that influences the industry at the highest level. In addition to publishing insideARM.com, the iA Institute runs the Compliance Professionals Forum (a membership organization that provides context and practical support for day-to-day compliance challenges), and manages the Consumer Relations Consortium (an extremely active group of nearly 30 larger market participants who discuss evolving practices, and regularly engage with consumer advocates and regulators to affect industry rulemaking).
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New York State has released new proposed Cybersecurity Requirements for Financial Services Companies. The proposal is extensive. Your IT leaders should review it in detail. Also note – the regulations would require annual Board review and certification.
Last week the 5th Circuit Court of Appeals ruled for the Plaintiff in Daugherty v. Convergent Outsourcing Incorporated; LVNV Funding, LLC, a case about what a collection letter did not say.
The Weekly Standard has just published an article written by attorney and former regulator Ronald L. Rubin that you will want to read. In the post, Rubin shares his insider experience as a former enforcement attorney with the CFPB, leading one of the Bureau’s first two debt collection investigations.
The United States Government Accountability Office (GAO) released a report last week that found that small business representatives (SERs) participating in the Consumer Financial Protection Bureau’s (CFPB) recent SBREFA processes thought they were too rushed. According to the report, the Regulatory Flexibility Act requires CFPB to convene Small Business Review Panels (also known as SBREFA panels) for rulemaking efforts […]
On August 4, 2016 the CFPB released a rule providing safe harbors from liability under the FDCPA for certain actions taken in compliance with mortgage servicing rules, but after the consumer has made a cease communication request. This will interest the ARM industry more broadly as it may signal a willingness to provide safe harbor where notification requirements are in conflict with the consumer’s interests.
According to an article in the Chicago Sun Times today, Illinois Governor Bruce Rauner vetoed a bill last Friday that would have allowed Cook County and Chicago to use third party debt collectors to pursue delinquent tax debts. Evidently, Rauner felt that this would “penalize property owners who are already facing skyrocketing property taxes.” The […]
This is the fourth in our series of “perspective” articles about the CFPB’s Outline of Proposed Debt Collection Rules, released last week. This post covers the subjects of litigation disclosure and time-barred and obsolete debt, which includes some of the most problematic proposals in the CFPB’s Outline for those who engage in litigation and/or collect late-stage or out-of-statute debt.
Amidst the whirlwind of information released in the last week by the CFPB regarding debt collection, you may have missed that – also last week – the CFPB’s Consumer Response division published a notice in the Federal Register for a “new information collection” aimed at further improving the complaint process for consumers and companies. NOTE: […]
Last week the CFPB released its 117-page Outline of Proposed Rules for debt collection in anticipation of the next step in rulemaking, the SBREFA panel, to be held on August 25th. insideARM is breaking down those proposals for our readers in a series of posts covering the range of topics addressed. Our first post – insideARM Perspective […]
The Consumer Financial Protection Bureau (CFPB) has released its long-awaited Outline of Proposed Rules governing third-party debt collectors. The proposal, released in advance of today’s 2:00 PM EDT CFPB Debt Collection Field Hearing in McClellan Park, California, is 117 pages and covers a wide range of topics that had been raised nearly three years ago […]