On December 10, 2024, the FTC adopted amendments to the Telemarketing Sales Rule (TSR) that extend the Rule's applicability to inbound telemarketing calls in response to an advertisement through any medium or direct mail solicitation in which technical support products or services are offered for sale. The amendments will become effective on January 9, 2025.

Dec 17
Dec 17 CFPB Spring 2024 Semi-Annual Report to Congress

Adam Witmer

Regulatory Update

On December 10, 2024, the CFPB released its semi-annual report for the Spring of 2024. This version of the regular report to Congress covers the period beginning on October 1, 2023, and ending on March 31, 2024.

Dec 16
Dec 16 CFPB Takes Action Against Performant Recovery for Illegal Fee Generating Scheme

Adam Witmer

Regulatory Update, UDAAP

On December 9, 2024, the CFPB took action against student loan debt collector Performant Recovery Inc. for illegal fee-generating scheme that cost borrowers thousands of dollars Performant Recovery, Inc. collected on student loan debt, including from borrowers who had defaulted on Federal Family Education Loan Program (FFELP) loans.

Dec 16
Dec 16 CFPB to Address Financial Impact of Domestic Violence and Elder Abuse

Adam Witmer

Regulatory Update, FCRA

On December 9, 2024, the CFPB issued an Advance Notice of Proposed Rulemaking to address the harmful effects of inaccurate credit reporting affecting survivors of domestic violence, elder abuse, and other forms of financial abuse. The Bureau aims to gather additional public input on potential amendments to the regulation that implements the Fair Credit Reporting Act (FCRA).

Dec 16
Dec 16 CFPB Sues Comerica Bank for Systematically Failing Disabled and Older Americans

Adam Witmer

Regulatory Update

On December 6, 2024, the CFPB sued Comerica Bank for systematically failing its 3.4 million Direct Express cardholders - primarily unbanked Americans receiving federal benefits. According to the CFPB, the bank disconnected 24 million customer service calls, charged illegal ATM fees to over 1 million customers, and mishandled fraud complaints related to the Direct Express prepaid debit card program.

Dec 11
Dec 11 FFIEC Proposes Rule Concerning AMC Regulatory Programs

Adam Witmer

Regulatory Update

On December 6, 2024, the Appraisal Subcommittee (ASC) of the FFIEC issued a proposed rule to implement a framework to govern the ASC's enforcement authority regarding the effectiveness of Appraiser and Appraisal Management Company (AMC) Programs overseen by State Appraiser Regulatory Agencies. The proposed rule would codify the existing ASC compliance review process consistent with the ASC's current practices and processes for conducting compliance reviews, with some modifications and minor corrections.

Dec 11
Dec 11 CFPB Sues Climb Credit and 1/0 for Deceptive Coding Bootcamp Loans

Adam Witmer

Regulatory Update, UDAAP

On December 5, 2024, the CFPB took action against student lender Climb Credit and its investors, including 1/0 (“One Zero”), filing a proposed order, which if entered will require the companies to stop making representations in their advertising about the quality of the training programs at their partner schools and graduates’ hiring rates and salaries. Climb Credit, Inc. is a Delaware corporation headquartered in Las Vegas, Nevada that markets private student loans.

Dec 10
Dec 10 CFPB to Distribute $1.8 Billion to Millions of Americans Harmed in Massive Credit Repair Scheme

Adam Witmer

Regulatory Update

On December 5, 2024, the CFPB announced that it is distributing $1.8 billion to 4.3 million consumers charged illegal advance fees or subjected to allegedly deceptive bait-and-switch advertising by a group of credit repair companies including Lexington Law and CreditRepair.com. According to the CFPB, payments to victims of Lexington Law and CreditRepair.com are the largest-ever distribution from the CFPB’s victims relief fund.

Dec 9
Dec 9 CFPB Proposes Rule to Prevent Data Brokers from Selling Sensitive Data to Scammers and Spies

Adam Witmer

Regulatory Update

On December 3, 2024, the CFPB proposed a rule to rein in data brokers that sell Americans' sensitive personal and financial information. According to the CFPB’s press release, the proposed rule would limit the sale of personal identifiers and make sure that people’s financial data is only shared for legitimate purposes.

Dec 9
Dec 9 Federal Court Suspends Beneficial Ownership Reporting Rule

Adam Witmer

BSA, Regulatory Update

On December 3, 2024, the ABA Banking Journal reported that a federal judge in Texas had issued a preliminary injunction blocking enforcement of the beneficial ownership reporting rule. This is less than a month before the January 1, 2025 deadline for businesses to report their beneficial owners to FinCEN.

Dec 17
Dec 17 FTC Amends Telemarketing Sales Rule

Dec 17
Dec 17 CFPB Spring 2024 Semi-Annual Report to Congress

Dec 16
Dec 16 CFPB Takes Action Against Performant Recovery for Illegal Fee Generating Scheme

Dec 16
Dec 16 CFPB to Address Financial Impact of Domestic Violence and Elder Abuse

Dec 16
Dec 16 CFPB Sues Comerica Bank for Systematically Failing Disabled and Older Americans

Dec 11
Dec 11 FFIEC Proposes Rule Concerning AMC Regulatory Programs

Dec 11
Dec 11 CFPB Sues Climb Credit and 1/0 for Deceptive Coding Bootcamp Loans

Dec 10
Dec 10 CFPB to Distribute $1.8 Billion to Millions of Americans Harmed in Massive Credit Repair Scheme

Dec 9
Dec 9 CFPB Proposes Rule to Prevent Data Brokers from Selling Sensitive Data to Scammers and Spies

Dec 9
Dec 9 Federal Court Suspends Beneficial Ownership Reporting Rule

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