The Report examined internal CFPB documents relating to the December 2013 consent order against the auto finance company Ally Financial Inc. and its subsidiary Ally Bank. The Report stated the CFPB purposefully chose to distribute the $80 million dollars in Ally Bank settlement funds “without verifying that recipients [were] eligible to receive the money.”
In a January 15, 2016 article in American Banker Magazine (Banks Can Use ‘Code of Ethics’ to Strengthen Public Trust), Robert Taylor points out “…an advantage of developing an ethics code is that, unlike bank regulatory policy that must be adjusted constantly depending on the jurisdiction and interpretation, ethical standards are basically timeless. In fact, […]
The CFPB has been highly emphatic in requiring both the financial services and the debt collection industry to increase compliance by establishing and maintaining systems and procedures to ensure consumer data privacy in all transactions. All of which have utilized “automated” systems that have proven to be effective and efficient in the credit ecosystem. Millions have been spent by the industry to meet these demands in the past 5-7 years. The National Creditors Bar Association (NARCA) members report a 300%+ increase in compliance costs from 2011-2014.
Last week was the International Association of Commercial Collectors’ (IACC) annual convention in Miami, FL. Having spoken at this conference in the past, I’ve always enjoyed my participation with this organization. When I reviewed the agenda for this year’s event, their keynote speaker jumped off the page at me. Retired Tuscon Police Department Captain and […]
It has become imperative for organizations storing sensitive data to diligently monitor and protect their assets. We are all continually asked to do more with less, but more than 70 percent of the average IT department’s time is spent keeping the lights on, limiting its ability to work on strategic projects that can enhance business […]
This week, former CFPB Student Loan Ombudsman Rohit Chopra started a new job — at the Department of Education. An outspoken critic of, well, just about everything related to student loans, one thing is clear: things will probably change at the Department of Education.
In this episode of the Debt Collection Drill podcast, attorneys John Rossman and Mike Poncin identify challenges arising from industry regulators and from the Courts while providing specific guidance on how best to avoid difficulties. Specifically: Regulators and Litigation.
Three weeks ago insideARM wrote about the latest developments in the Department of Education (ED) Debt Collection Services RFP. Now that the holiday season is over it is time to examine the impacts of that news. Interested companies are in full-fledged scramble mode. Initial questions were due on December 21st. Most industry people expect ED responses […]
Policies and Procedures are here to stay and will become the heartbeat of your organization. Aside from all the elaborate ways of writing policies and understanding the right approach to use when developing procedures, one must first consider and understand how they will impact the health of your organization from a different angle.
Let it be remembered that on December 28, 2015, the Consumer Financial Protection Bureau (CFPB), a bureaucracy manufactured by the Dodd-Frank Act of 2010, put to final rest the long established, fundamental principle that an attorney licensed to practice law by the highest court in the lawyer’s state had earned the title of a “learned […]