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Insights

Today's Trends in Credit Regulation

Welcome to Hudson Cook Insights - a collection of articles written each month by the attorneys of Hudson Cook, LLP, in an effort to keep their clients and other compliance professionals informed about current trends and developments in consumer credit finance that will affect the way they do business.

December 2017/January 2018

Deceptive Advertising: FTC Proposed Settlement Requires Spanish-language TILA Disclosures in Spanish-language Advertising

By Nora Udell

Cowboy AG, LLC, a Texas buy-here-pay-here dealer doing business as Cowboy Toyota and Cowboy Scion ("Cowboy"), has agreed to settle Federal Trade Commission ("FTC") charges that it used deceptive advertisements in a regional Spanish-language newspaper. The FTC published a description of the proposed settlement agreement in the Federal Register for public comment on December 8, 2017. The FTC will decide whether to accept the proposed agreement or take other action against Cowboy after it reviews the comments. The comment period closed on January 2, 2018. article continued

CFPB Notches CashCall "Win" with Significant Loss

By Allen H. Denson

On January 19, 2018, the U.S. District Court for the Central District of California issued its findings of fact and conclusions of law in CFPB v. CashCall, Inc., following the bench trial that occurred in late 2017. Although the Bureau technically "won" the case, the court's decision represents a significant setback for the Bureau in terms of its available remedies. By way of background, CashCall was the assignee of online loans that were purportedly originated under the laws of a federally recognized Indian tribe. The CFPB alleged that CashCall was the "true lender" for such loans and obtained partial summary judgment on this issue in 2016. A trial solely on the issue of remedies followed, and the court's opinion solely concerned whether the CFPB was entitled to the nearly $300 million it sought in combined restitution and penalties. article continued

Rich Cordray's Legacy and the Future of the CFPB

By Lucy E. Morris

The day after Thanksgiving, Richard Cordray stepped down as head of the Consumer Financial Protection Bureau. I worked with Rich to 'stand up' the Bureau and as a deputy enforcement director. In the summer of 2014, after four years at the Bureau, I decided to leave the agency. I wanted to tell Rich immediately and waited until what I thought was a reasonable hour - 10 a.m. - to call him. He answered in a whisper: "Lucy, Lucy, how are you?" He then explained in a hush that it was 7 a.m. in California, where he was vacationing, and that his family was still sleeping. I was embarrassed to catch him at such an early hour, on his vacation, but he welcomed my call. I then started to tell him my news, only to lose the connection in mid-sentence. I tried back, but it happened again and again. After about four attempts to connect, I stopped trying, not wanting to bother Rich any further. article continued

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