On 4 August 2014, the Office of the Comptroller of the Currency (“OCC”) issued guidance to national banks and federal savings associations (collectively “banks”) on the application of consumer protection requirements and banking practices to consumer debt-sale arrangements with third parties that intend to pursue collection of the underlying obligations.

Among other things, the OCC guidance emphasizes that: (i) a bank must have in place appropriate internal policies and procedures that govern debt-sale arrangements consistently across the bank; (ii) banks must be performing appropriate due diligence when selecting debt buys; (iii) banks must provide accurate and comprehensive information regarding each debt sold, at the time of sale; (iv) banks must ensure compliance with applicable consumer protection laws and regulations; and (v) banks must implement appropriate oversight of debt-sale arrangements.

The full text of the OCC bulletin is available at: http://www.occ.gov/news- issuances/bulletins/2014/bulletin-2014-37.html.