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.
When consumers face hard times, creditors will often try to provide alternative payment arrangements to help them continue to make payments on their loans. When payment arrangements deviate from the contractual obligations, there is potential for consumer confusion about what information should appear on their credit reports. A recent case handed down by the U.S. Court of Appeals for the Eleventh Circuit has some important lessons for creditors who offer alternative payment arrangements. article continued
The Federal Reserve Board and the Federal Reserve Bank of Cleveland recently released the results of a study on alternative funding to small businesses in a report titled, "Browsing to Borrower: 'Mom & Pop' Small Business Perspectives on Online Lenders," available here. The study results provided an informative look at the concerns of small-business owners about online funders, owners' preferred funding sources, and what owners looked for in a funder. article continued
Looking for a way to reduce losses, you may have heard that some dealerships are collecting fingerprints, both electronically and with ink and paper, from consumers who want to take a test drive. At first blush, it seems like a good idea to protect against theft of demonstrator vehicles (and to assist law enforcement in the event of a loss). But before adopting this as your dealership's next loss prevention strategy, take some time to consider the privacy implications and your state's laws. article continued
The White House nominated Kathleen Kraninger to be the new director of the Bureau of Consumer Financial Protection. Currently the Associate Director for General Government in the Office of Management and Budget (i.e., deputy to OMB and Interim BCFP Director Mick Mulvaney), Kraninger was not among the names rumored to have been on the short list for the job and is a bit of a surprise from a financial policy perspective. article continued
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