Keeping up with State Licensing and Enforcement Activity is Becoming a Full-Time Job For Collection Agencies

The ARM industry, and collection agencies specifically, are subject to regulation (and potential enforcement actions) from the Consumer Financial Protection Bureau (CFPB), the Federal Trade Commission (FTC), many states, and some cities.  Keeping up with potential changes can be challenging.  Some recent examples include the following.

Montana

On February 23, 2016 the State of Montana, Department of Administration, Division of Banking & Financial Institutions, issued a Memorandum that included the following opinion regarding the Montana Consumer Loan Act (Act):

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