The United States Department of Housing and Urban Development has issued a partial waiver of 24 CFR 203.604, the provision that requires mortgagees to establish face-to-face contact with borrowers during default and loss mitigation intervention. This suspension, which is stated to last for one year, was issued in response to public concerns over the spread
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 19, 2020, New York Governor Andrew Cuomo announced a series of measures designed to ease the economic impact of COVID-19. Most notably to the consumer financial services industry, Cuomo announced that New York would “offer 90-day relief on mortgage payments. Waiving mortgage payments based on financial hardship.” He also said the state would
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 17, the Consumer Financial Protection Bureau ordered all employees – not just those in the most affected regions – to begin working from home given the rapid spread of the coronavirus (“COVID-19”). CFPB Director Kathleen Kraninger sent an email to all CFPB employees in the evening of March 17 stating that a prior
Certain government regulatory bodies have produced new guidance for financial institutions in light of the coronavirus (“COVID-19”) pandemic. The Federal Reserve Board, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, National Credit Union Administration, and the Conference of State Bank Supervisors (known as the “Prudential Regulators”) have encouraged
Applying the definition of an automatic telephone dialing system required by the recent Eleventh Circuit decision Glasser v. Hilton Grand Vacations Co., LLC, Judge Charlene Honeywell from the United States District Court for the Middle District of Florida held in Northrup v. Innovative Health Ins. Partners, LLC, et al., that the Twilio
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