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Chris focuses his practice on consumer financial services compliance, guiding clients through the many federal and state laws and regulations that impact consumer credit programs.

In late September, the Department of Justice (DOJ) entered into two consent orders to resolve allegations related to violations of the Servicemembers Civil Relief Act (SCRA). The past year has seen an uptick in regulatory scrutiny centered on military consumer protection laws. The DOJ’s recent consent orders highlight this trend.

The SCRA provides various legal

On September 21, the U.S. Senate voted 49-48 along party lines on a procedural motion to advance the nomination of current Federal Trade Commission (FTC) Commissioner Rohit Chopra to become the director of the Consumer Financial Protection Bureau (CFPB). Commissioner Chopra’s nomination had been in limbo since March, when the Senate Banking Committee failed to

On August 27, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the “Agencies”) issued “Conducting Due Diligence on Financial Technology Companies: A Guide for Community Banks.” While the guide is primarily intended to help community banks assess risks

On August 16, the Consumer Financial Protection Bureau (CFPB) filed a proposed settlement to resolve a lawsuit against a debt collection firm, Fair Collections & Outsourcing (FCO), and its owner, Michael Sobota, stemming from FCO’s alleged failure to implement proper policies and procedures, in addition to related Fair Credit Reporting Act (FCRA) and Fair Debt

On August 31, the New York Department of Financial Services (DFS) issued an industry letter to all supervised mortgage lending institutions and their affiliates on preventing sexual orientation discrimination in mortgage lending. New York’s Fair Lending Law prohibits discrimination in, among other things, the granting, withholding, extending, or renewing, or in the fixing of the

On August 11, the Consumer Financial Protection Bureau (CFPB) published a notice and request for comment in the Federal Register on its information collection initiative, “Electronic Disclosure on Mobile Devices.” The CFPB issued the request for comment in advance of seeking formal approval for the initiative from the Office of Management and Budget (OMB).

The

On August 11, the Federal Financial Institutions Examination Council (FFIEC) issued guidance, titled “Authentication and Access to Financial Institution Services and Systems,” which provides financial institutions with examples of effective authentication and access risk management principles and practices for customers (both business and consumer), employees, and third parties accessing digital banking services and