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CFPB Debt Collection Plan Doesn't Spare Banks

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?

Misleading Collection Scripts Cost Financial Institution $28.5 Million

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?

Misleading Collection Scripts Cost Financial Institution $28.5 Million

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?

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Signature card and substitute W-9 info

04/13/2025

I have a single member LLC that is not a disregarded entity. I have an EIN letter that says single member. Should my signature card show Single Member LLC or LLC (LLC tax classification)?

Banking marijuana-related businesses

04/06/2025

Our bank has taken a "no" stand on banking MRBs, however we recognize the "Tier III" category identifies some types of businesses that may provide services to a Tier I MRB. An example would be a container manufacturing company that may sell containers to a Tier I MRB as only a small percentage of their business. Does anyone use an allowable percentage of revenue to determine if this is within your risk tolerance? Also, is there an allowable threshold for direct sales of cannabis products in the states that have legalized use? (For instance, a liquor store or distributor that sells beverages with THC, since that is becoming so common).

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