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On July 21, Acting Director Dave Uejio celebrated the 10-year anniversary of the Consumer Financial Protection Bureau (CFPB) by giving prepared remarks highlighting the CFPB’s activities over the past 10 years in enforcement, consumer empowerment, and racial equity, as well as its response to the COVID-19 pandemic. Uejio advised that the CFPB’s enforcement and supervision work has resulted in approximately $14.4 billion in consumer relief and that its enforcement actions have resulted in $1.7 billion in civil penalties; however, he notes that there is much more to be done in enforcement.
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Many finance companies, debt buyers, debt collectors, and collection law firms wrestle with the question of which statute of limitations to apply when collecting a deficiency balance on a retail installment contract. States often have different statutes of limitations for contracts or written promises to pay money than they do for sales of goods, like motor vehicles. A RIC is a credit agreement that evidences a sale where the buyer agrees to pay in installments, most often subject to a finance charge (interest). The RIC is not the only document memorializing the sale. In fact, it is not even the primary sale document; that s the buyer s order, purchase agreement, or bill of sale. But, by its nature, the RIC is about equal parts a sale agreement and a financing agreement, and those components are wound together tightly in the contract.
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