Part Three: Risk Reward Will Always be Part of the Subprime Future
This article was originally published in the May 2021 issue of
Texas Dealer magazine, pages 19-20. It is the final article of an exclusive three-part series interview with Jean Noonan, member of the CFPB Taskforce on Federal Consumer Law. Parts one and two can be found in the March and April issues of
Texas Dealer, respectively. The entire article series can be found on the TIADA website under Knowledge Base.
We resume our conversation where we left off on Part Two with a question citing the Taskforce report with recommendations for improved financial protection program.
By
Troutman Pepper Hamilton Sanders LLP issued the following announcement on Apr. 6.
David Anthony, a partner in Troutman Pepper’s Consumer Financial Services Practice Group, was recently elected a Fellow in the American College of Consumer Financial Services Lawyers. The College is a professional association of lawyers who have made significant contributions to the field of consumer financial services law, exhibit great skill and expertise in handling consumer financial services matters, and are dedicated to improving the practice of consumer financial services law.
As a Fellow, Anthony joins a select association of consumer financial services lawyers who, by reason of their character, skill, and ability, contribute to the accomplishments and good fellowship of the College.
We resume our conversation where we left off on Part One with a question citing the Taskforce report with recommendations for improved financial protection program.
Texas Dealer: The report states: DOOR-TO-DOOR SALES In any contract for the sale of goods entered into outside the creditor s place of business and payable in more than four installments, the debtor should be able to cancel the transaction at any time prior to midnight of the third business day following the sale.
As you are aware, door-to-door sales statutes were originally designed to combat shady door-to-door salesmen and car dealers were excluded from the federal door-to-door rescission law. Today consumers are reaching out over the internet to car dealers from numerous states with various state statutes modeled after the federal law and some of those laws are less clear as to applicability. Would you care to share your view on the application of door-to-door statutes to internet sales?
Each month, we host a 30-minute
webinar outlining the month s key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month s article, we share some of our top bites covered during the January 26 webinar.
So what happened at the CFPB in the past month? A whole lot.
Bite #10 - Settled with a mortgage servicer.
The CFPB settled with a mortgage servicer over alleged violations of the Consumer Financial Protection Act and Regulation Z in relation to processing loss mitigation applications. The CFPB claimed that the mortgage servicer violated the CFPA by:
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The Consumer Financial Protection Bureau (CFPB) released its long-awaited two-volume Taskforce Report on Consumer Financial Law (the Report) as expected last week, following a yearlong effort. While advisory in nature, it is written with an intent to influence consumer finance law for decades to come. And while the Taskforce was criticized for lacking any consumer advocates among its members, the Report more often than not generally expands in detail on themes that could have fit just as well in Obama-era reports or views we expect to see expressed in a CFPB led by a Biden administration appointee. We explain in detail below.