On March 22, the Board of Governors of the Federal Reserve System (“FRB”), Federal Deposit Insurance Corporation, National Credit Union Administration, Office of Comptroller of the Currency, Consumer Financial Protection Bureau, and the Conference of State Bank Supervisors (collectively, “the Agencies”) issued an interagency statement, available here, providing guidance for lenders on how to
On March 13, two days after the World Health Organization announced that the coronavirus (“COVID-19”) outbreak could be characterized as a pandemic, the White House declared the outbreak a national emergency.
In response, the Consumer Data Industry Association (“CDIA”) provided guidance for lenders and creditors who report information about consumers whose accounts are
Like most industries today, Consumer Financial Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Sanders and Pepper Hamilton have developed a dedicated COVID-19 Resource Center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19 news and developments, recommendations from leading health organizations, and tools
On March 17, a bill was introduced in the United States Senate to amend the Fair Credit Reporting Act to prohibit negative credit reporting during the coronavirus health crisis. The bill, S.3508, is entitled The Disaster Protection for Workers’ Credit Act. It would provide for a four-month moratorium on negative credit reporting and a
On March 6, the Federal Trade Commission filed a complaint in the United States District Court for the District of Colorado against BoostMyScore LLC (“Boost”), BMS, Inc., and William O. Airy – the principal operator of both Boost and BMS. The complaint alleges that the defendants violated the FTC Act, Credit Repair Organizations Act, and
On February 27, 2020, the United States Court of Appeals for the Ninth Circuit issued its decision in Ramirez v. TransUnion LLC, a class-action case watched closely by consumer reporting agencies and other persons regulated by the Fair Credit Reporting Act (“FCRA”). In Ramirez, the Court held for the first time that all
Please join Troutman Sanders attorney’s David Anthony, Tim St. George, and Scott Kelly for the complimentary webinar, “2019 in Review: Key Developments for Background Screeners and Companies Subject to the FCRA” on March 4th from 3-4 pm ET.
Lawsuits alleging violations of the Fair Credit Reporting Act (“FCRA”), including background-check related litigation, have
Plaintiff Amanda Groettum may be alive and well, but in Groettum v. Kohl’s Department Stores, Inc., the United States District Court for the District of Minnesota laid to rest her claims under Minnesota’s credit defamation laws and any contention that the Fair Credit Reporting Act’s two preemption provisions are in conflict.
In her complaint,
On Friday, the Consumer Financial Protection Bureau (CFPB) published a supplement to its Spring 2019 notice of proposed rulemaking on third-party debt collection. The proposed supplemental rule addresses the collection of time-barred debt, which is debt that has run past any applicable statute of limitations.
Specifically, the proposed supplemental rule requires debt collectors to make
2019 was a transformative year for the consumer financial services world. As we navigate an unprecedented volume of industry regulation, Troutman Sanders is uniquely positioned to help its clients find successful resolutions and stay ahead of the compliance curve.
In this report, we share developments on consumer class actions, background screening, bankruptcy, consumer credit