Like most industries today, Consumer Finance 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
CCPA Regulations Likely Not Effective Until October 1
Authors:
Wynter Deagle
Sharon Klein
Alex Nisenbaum
Ron Raether
Anne-Marie Dao
Sadia Mirza
Businesses awaiting final California Consumer Privacy Act (CCPA) regulations will likely be waiting until after enforcement of the CCPA begins on July 1.
Prior to the regulations taking effect, the attorney general must submit proposed regulations to the state Office of Administrative
U.S. House Democrats Still Pushing for Debt Collection Moratorium
The Democrats on the House Financial Services Committee are pushing their proposed package of bills aimed at responding to the coronavirus (“COVID-19”) pandemic. This time around, they are supporting the bill that would place a moratorium on debt collection activities for the duration of the pandemic.
A May 5 release from the Democrats on the
FTC Settles with Online Game Developer Regarding Allegations Concerning Children’s Privacy
Miniclip, S.A., a Swiss-based company developing online games, recently settled with the Federal Trade Commission over false claim allegations made in connection to the Children’s Online Privacy Protection Act (“COPPA”). In its complaint, the FTC alleged that Miniclip falsely claimed to be a valid member of the Children’s Advertising Review Unit’s (“CARU”) COPPA safe harbor
Ransomware Attacks Amid COVID-19
There is never an opportune time to be the victim of a ransomware attack, but with the growing impact that COVID-19 is having on businesses and the increased pressure they already face, a ransomware attack in today’s environment could certainly prove to be disastrous. Cybercriminals are leveraging the pandemic for their commercial gain and we
Fifth Circuit Affirms Summary Judgment for Plaintiff in Time-Barred Debt Case
The United States Court of Appeals for the Fifth Circuit recently held that certain letters seeking collection of time-barred debt by using “ambiguous offers and threats with no indication that the debt is old, much less that the limitations period has run, misrepresent the legal enforceability of the underlying debt in violation of” the Fair
FTC Releases Tips to Combat Contact-Tracing Scammers
As the coronavirus (“COVID-19”) testing increases across the country, state health departments have been implementing contact tracing to contain viral spread. Contact tracing identifies and monitors individuals who have come into contact with others who have tested positive for COVID-19. Typically, contract tracers work with infected individuals to obtain the contact information for everyone with
Troutman Sanders Weekly Consumer Financial Services COVID-19 Newsletter – May 18, 2020
Like most industries today, Consumer Finance 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
CFPB Releases New Documents Outlining Responsibilities of Financial Firms During COVID-19 Pandemic
On May 13, the Consumer Financial Protection Bureau released two new FAQ documents outlining responsibilities of certain financial firms during the coronavirus (“COVID-19”) pandemic, and a statement regarding billing error responsibilities of credit card issuers and other open-end non-home secured creditors.
The first new FAQ document is entitled, “The Bureau’s Payments and Deposits Rules FAQs
Tenth Circuit Develops New ERISA Rule in Ellis v. Liberty Assurance Company of Boston
The Tenth Circuit developed a new rule under the Employee Retirement Income Security Act of 1974 (ERISA) in Ellis v. Liberty Assurance Company of Boston (case number 19-1074), holding last week that courts should adhere to choice-of-law provisions in ERISA health benefits plans.
In Ellis, the Tenth Circuit considered whether Michael Ellis’ health benefits