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Sirote & Permutt PC | USA | 11 Jun 2019

BACK TO BASICSCan You Name all the Federal Consumer Finance Policies that are Applicable to Consumer Loan and Credit Sales Companies

Last week I listed 9 separate federal law notices that may be required in a consumer credit transaction. See here. I was striving for 10. So far no


Sirote & Permutt PC | USA | 7 Feb 2019

Traditional Installment Lenders Should Continue To Be Concerned About The Newly Released CFPB Payday Loan Rule

On Wednesday, February 6, 2019, the Consumer Financial Protection Bureau released its updated Payday Lending RulePayday, Vehicle Tile, And Certain


Sirote & Permutt PC | USA | 24 Oct 2018

Back to Basics, ContinuedComplaints and the BCFP Portal

My partner, Sam Friedman and I have frequently written about the importance of handling customer complaints. Sam likens customer complaints to the


Sirote & Permutt PC | USA | 27 Aug 2018

GLBA Privacy Notice Changes: Well, that was FAST

Earlier this month, the Bureau of Consumer Financial Protection finalized amendments to the Gramm-Leach-Bliley Act (GLBA) Privacy Notice Regulations


Sirote & Permutt PC | USA | 23 May 2018

Back to Basics, Continued: Enough About Credit ReportingLet's Talk About Two FTC Rules!

In the era before there was a CFPB, the Federal Trade Commission (“FTC”) was one of the two important federal regulators of our industry. The FTC and


Sirote & Permutt PC | USA | 26 Apr 2018

What's Different about the CFPB, I mean, the Bureau?

Well, just about everything is different about the CFPB. Not only is there a new official seal, but, apparently the CFPB has adopted a new moniker


Sirote & Permutt PC | USA | 12 Apr 2018

Stick to Your Knitting

There is a titanic battle over the Consumer Financial Protection Bureau going on in Washington. One side is led by Congressional Republicans who have


Sirote & Permutt PC | USA | 20 Feb 2018

What Is The Next Big Threat To Consumer Finance Companies?

Well, surprisingly, the next big threat to consumer finance companies comes not from plaintiffs' lawyers, nor from state regulators, nor from the CFPB


Sirote & Permutt PC | USA | 13 Dec 2017

Reflections on the CFPB Blogosphere

In 2014, we started our Sirote Consumer Finance Blog about the CFPB and the subject of consumer credit compliance. Recall that the CFPB was just then


Sirote & Permutt PC | USA | 19 Oct 2017

CFPB's Batting Average on Significant Consumer Financial Services Regulations Stands At .666

Well, if you consider that the CFPB has been up to plate with three significant rulemakings aimed at traditional installment lenders, and have

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