Troutman Sanders has been closely monitoring the Centers for Disease Control and Prevention and other world authorities’ updates and recommendations regarding the novel coronavirus (COVID-19).
All Troutman Sanders’ lawyers and staff have been strongly encouraged to work remotely beginning Tuesday, March 17. Essential on-site services will be maintained in each office. We have no known
Another Circuit Court of Appeals has weighed in on the constitutionality of the Consumer Financial Protection Bureau’s structure, on the very day that the Supreme Court of the United States heard argument on the same question. In CFPB v. All American Check Cashing, Inc., et al, a divided panel of the Fifth Circuit held
The Safeguards Rule of the Gramm-Leach-Bliley Act of 1999 requires financial institutions to implement security programs in order to keep customer information secure. The Safeguards Rule also extends contractually to affiliates and/or service providers of those financial institutions, including possibly “finders” (i.e., entities charging a fee to connect consumers looking for loans to lenders).
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On April 22, 2020, Troutman Sanders attorneys, Maryia Jones and Stephen J. Steinlight, will serve again on the faculty for their webinar series by Lorman Educational Services entitled, “Collection Disputes: A Good Defense Is the Best Offense.”
The credit and collection industry remain under an increased scrutiny from regulators and legislators and
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 25, the Federal Trade Commission – the nation’s primary privacy and data security enforcer – released its latest Privacy and Data Security Update, which summarizes the agency’s privacy and data security activities over the last year and provides a preview of what’s to come in 2020. Here are our top five takeaways
On February 26, the Consumer Financial Protection Bureau added ten FAQs concerning lender credits to its TILA-RESPA Integrated Disclosures (“TRID”) FAQs resource.
The new lender credit FAQs appear to be consistent with the industry’s current practices for managing and disclosing lender credits. They address topics such as:
The Federal Trade Commission’s Bureau of Consumer Protection division recently issued a staff perspective paper on the consumer protection issues facing small business financing. The paper follows the agency’s “Strictly Business” forum, held in May 2019, which examined trends in the marketplace, including online loans and alternative financing products. “The agency remains committed to protecting
On February 24, Judge Dale Kimball of the United States District Court for the District of Utah granted in part and denied in part a defendant debt collector’s motion for judgment on the pleadings. Plaintiffs Karl Buhler and Reginald Benoit, two Utah residents, filed a lawsuit against BCG Equities (BCG), claiming that it violated
In many of the settlement agreements and stipulated orders in the FTC’s recently released 2019 Privacy and Data Security Update, the FTC repeatedly imposed a set of uniform mandates for businesses to implement following a data breach. Businesses subject to the new California Consumer Privacy Act may be able to use this mandate to