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Consumer Financial Services UDAAP Round-Up: September 2021 - March 2022

USA - May 16 2022 Welcome to the latest edition of the UDAAP Round-Up. This newsletter is designed to provide you with a periodic resource to stay abreast of federal…

Christa L. Bieker, Julyana C. Dawson, Grace Kim, Ori Lev, Jedd P. Mellin, Stephanie C. Robinson, Brian J. Stief, Kerri Webb

US CFPB Re-Examines Its Supervisory Authority

USA - April 29 2022 On April 25, 2022, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) announced that it has begun using its authority to examine nonbank…

Christopher B. Leach, Ori Lev, Stephanie C. Robinson

US FTC Settlement With Auto Dealer Signals More Aggressive Fair Lending and UDAP Enforcement

USA - April 7 2022 On March 31, 2022, the Federal Trade Commission (“FTC”) and the Illinois Attorney General (“AG”) sued a group of auto dealers (“Napleton” or the…

Christopher B. Leach, Tori K. Shinohara

Debt Collectors and Loan Servicers’ Clear Message from Eleventh Circuit’s Hunstein Decision - Use of Third-Party Vendor Could Violate FDCPA

USA - April 29 2021 In a unanimous decision with potentially far-reaching implications for the loan servicing and debt collection industries, the United States Court of…

Christopher S. Comstock, Steven M. Kaplan, Thomas V. Panoff, Megan S. Webster

The Blurred Lines of Organizational Risk Management

USA - July 31 2020 On July 20, 2020, the Institute of Internal Auditors (“IIA”) finalized revisions to its three lines of defense (“3LOD”) model for risk management (now…

Matthew Bisanz, Jeffrey P. Taft, Megan S. Webster