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.

September 2020

It's the Final Countdown: The Small Dollar Rule's Looming Compliance Date

By K. Dailey Wilson

In July 2020, the Consumer Financial Protection Bureau ("Bureau") at long last finalized the Rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans ("Small Dollar Rule" or "Rule"). The Rule, originally proposed in 2016, has undergone a wild ride - from being "finalized" in 2017 to having substantial sections rescinded in 2020, including the mandatory underwriting provisions. As a result, all that remains are the "payment provisions." article continued

The City that Never Sleeps on Debt Collection: A Primer on New York City's Debt Collection Regulations

By Anastasia Caton and Tom Quinn

The New York City Department of Consumer and Worker Protection ("DCWP") (formerly the Department of Consumer Affairs) promulgated new debt collection rules this spring to provide protections to consumers with limited English proficiency. The new rules are intended to address concerns identified by the DCWP in its "Lost in Translation: Findings from Examination of Language Access by Debt Collectors" report that was issued in the fall of last year. article continued

Towing Companies Sued for Alleged SCRA Violations

By Charles F. Dodge, Jr.

In mid-August, the Department of Justice sued Target Recovery Towing Inc. and Target Recovery & Transport Inc. in Florida federal court for violating the federal Servicemembers Civil Relief Act when, without a court order, they sold a car to satisfy a storage lien. The car belonged to an active-duty servicemember deployed overseas. The case is only at the complaint stage, but it reflects an SCRA enforcement initiative different from others that typically make financial services news. article continued

New Features in the CFPB Consumer Complaint Database

By Eric D. Mulligan

On July 17, the Consumer Financial Protection Bureau added new features to its Consumer Complaint Database. The new "trends" features allow a user to view complaint data over time. While the database always allowed a user to filter complaints by date range, the new features make it easier for a user to see changes in overall complaint volume and complaints by type. If you want to see where you are and where you've been in terms of compliance, these new features may help. article continued

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