On July 7, the Consumer Financial Protection Bureau (CFPB) published a legal interpretation to ensure that companies that use and share credit reports and background reports have a permissible purpose under the Fair Credit Reporting Act (FCRA). The CFPB’s new advisory opinion makes clear that credit reporting companies and users of credit reports have specific obligations to protect the public’s data privacy. The advisory also reminds covered entities of potential criminal liability for certain misconduct. […]
Month: July 2022
FFIEC UPDATES LIST OF DISTRESSED OR UNDERSERVED GEOGRAPHIES
On July 1, 2022 the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency announced the availability of the 2022 list of distressed or underserved nonmetropolitan middle-income geographies. These are geographic areas where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration pursuant to the definition of community development under the agencies’ regulations. Revitalization or stabilization activities in these geographies are eligible to […]
CFPB TARGETS DEBT COLLECTOR CONVENIENCE FEES
On June 29, the CFPB issued an advisory opinion affirming that federal law prohibits debt collectors from charging “pay-to-pay” fees. These charges, commonly described by debt collectors as “convenience fees,” are imposed on consumers who want to make a payment in a particular way, such as online or by phone. The advisory opinion is based on language in Section 808 of the Fair Debt Collection Practices Act (FDCPA), which prohibits debt collectors from collecting any […]