Carly Souther is General Counsel and COO at iTrain OnDemand (iTod), where she provides guidance on legal and compliance issues for clients in the U.S. financial industry. She formerly served as Chief of Regulation at ECigIntelligence and was the Assistant General Counsel at Florida's Agency for Health Care Administration.
Carly has published on a wide range of issues in both legal and medical journals, including the Georgetown Journal on Poverty Law & Policy and the University of Iowa's Transnational Law & Contemporary Problems. She is a member of the Florida Bar, and holds an M.A. from the Universitat Autònoma de Barcelona; a J.D. from the Florida State University College of Law; and a B.A. from Mercer University.
04/28/2019
On October 17, 2018, the CFPB announced that it plans to issue a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA) this spring; the NPRM will likely have a dramatic impact on collection practices for debt collectors. But, what affect, if any, will it have on first-party creditors? What other regulatory concerns related to debt collection should my bank be aware of?
04/28/2019
Since 2014, the DOJ has brought numerous enforcement actions against businesses, including banks, whose websites and mobile applications weren't easily accessible for persons with disabilities and, therefore, were potentially non-compliant with the Americans with Disabilities Act (Act). In order to make their websites and apps more accessible for differently-abled people, what actions have these DOJ settlements required such businesses to take?
04/21/2019
How many banks have been sued under the ADA in federal court in 2019?
04/21/2019
In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?
04/14/2019
Does my bank's mobile app need to be compliant with the ADA?
04/14/2019
In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?
04/07/2019
Based on the CFPB's latest semiannual report, what are examples of topics of critical importance to the Bureau right now?
04/07/2019
For years, the Consumer Financial Protection Bureau (CFPB) has promised to prioritize rulemaking based on consumer complaints. Because debt collections account for nearly 1/3 of all consumer complaints, when can first-party collectors expect the Bureau to issue new rules?
04/07/2019
What is the DOJ's position on ADA website compliance under the Trump Administration?
03/31/2019
What is an example of a rule we can expect the CFPB to propose this year?