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Operational Impacts of the New CFPB Credit Card Late Fee Rule

On March 5, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final credit card late fee rule (the “Final Rule”), which, amongst other things, significantly reduces the late fee safe harbor cap for issuers other than “smaller card issuers” from the currently permitted $30 (and $41 for repeat violations) to a flat fee of $8 for all violations. In prior blogs, we have discussed the Final Rule and how it compares to Regulation Z and the previously Proposed Rule, and a legal challenge to the Final Rule brought by financial industry trade associations in a lawsuit and motion for preliminary injunction. Below, we discuss some of the operational impacts we expect to see when the Final Rule becomes effective.

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Credit-based triggers should be a core requirement for your business. 

Uncertain economic times and a higher volume of delinquencies has made managing your collection portfolio increasingly challenging. Implementing the right tools is critical. In their recent analytics study, Experian explores how Collections Triggers℠ works and how debt collectors effectively leverage them to prioritize accounts and increase recovery rates.  

Download now to learn more. 

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insideARM is grateful to our 2024 Strategic Supporters:

NCB Crown Asset Management Spring Oaks Capital

ConServe Cares Program Announces March Donation

ROCHESTER, N.Y. -- Continental Service Group, LLC d/b/a ConServe, in conjunction with the company’s “Matching Gift Program”, donated its March ConServe Cares proceeds to the American Heart Association. The ConServe team supports and funds the efforts of numerous local non-profit agencies that strive to make a difference. Due to the kindness and generosity of their employees, numerous lives in their community have been positively impacted and enriched.

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CFPB Order Makes it Clear: Nonbanks Should Prepare for CFPB Supervision

The CFPB recently published a decision and order subjecting a nonbank consumer lender to its supervisory authority based on its determination that the lender may be “engaging, or has engaged, in conduct that poses risks to consumers.”

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Improve Your Digital Contact Strategy with Email Append [sponsored]

Debt collectors added digital communications to their omnichannel outreach strategies as soon as regulators gave the green light on emailing, texting and other forms of digital communication. While each channel has its pros and cons, testing can help you identify which channel may work best for different types of consumers. For example, some people may be more likely to open and respond to emails than a text or letter. Emailing can also be less expensive than sending texts, direct mail or making phone calls. To successfully incorporate email and ensure right-party contact, you need a verified and up-to-date email list.

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insideARM Weekly Recap- Week of March 25, 2024

There is never a shortage of news in the world of debt collection. At insideARM, we try to help you stay on top of the most crucial news by bringing you one piece of relevant news each day. We publish articles covering topics our editorial team thinks are the most important for ARM industry professionals to stay compliant while increasing revenue. That said, even with a streamlined news source, it can be difficult for even the most organized person to stay on top of what is going on in an industry that is changing rapidly. So, starting today and continuing weekly on Mondays, we are going to bring you the insideARM Weekly Recap, a synopsis of everything we highlighted during the week and why our editorial team thinks you should know about it.

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CFPB and FTC Amicus Brief Signals Stance on “Pay-to-Pay” Fees Under FDCPA

On February 27, the Consumer Finance Protection Bureau (CFPB) and the Federal Trade Commission (FTC) filed an amicus brief in the 11th Circuit case Glover and Booze v. Ocwen Loan Servicing, LLC arguing that certain convenience fees charged by mortgage servicer debt collectors are prohibited by the Fair Debt Collection Practices Act (FDCPA).  This brief comes on the heels of an amicus brief Alston & Bird LLP filed on behalf of the Mortgage Bankers Association (MBA).  In its brief, the MBA urged the 11th Circuit to uphold the legality of the fees at issue.

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Help Wanted: Predictive, Collaborative and Intelligent Contact Data

25 April 2024 at 03:00 p.m.

When your contact data isn’t meeting expectations, your organization lags behind. In this webinar by TransUnion, we'll discuss transformative technologies to make your data smarter and more strategic to optimize customer communications.

Event Details »