On December 23, 2020, the New York Governor signed the bill that requires specific disclosures be provided in certain commercial financing transactions. See our prior ALERTS dated Dec. 14, 2020 and Sept. 15, 2020 for details of the law’s requirements. Financial institutions are exempt from the disclosure requirements…Read More
Month: December 2020
THE CFPB RELEASES PART TWO OF THE FEDERAL DEBT COLLECTION RULE
On December 18th, the Consumer Financial Protection Bureau (“CFPB”) released part two of its federal debt collection rule (known as “Regulation F,” to be codified at 12 C.F.R. Part 1006) under the federal Fair Debt Collection Practices Act (“FDCPA”). Part two focuses on debt validation information, time-barred debts, certain credit reporting in collections and deceased consumers. Part two of the final rule becomes effective on the same date as part one of the final rule — November 30, 2021…Read More
MULTIPLE CRYPTOCURRENCY COMPANIES APPLY FOR OCC BANK CHARTER
Over the past month, three cryptocurrency companies filed for a bank charter with the Office of the Comptroller of the Currency (“OCC”).
In November, Anchorage, a digital asset custodian, filed an application for a national trust charter with the OCC. Anchorage’s General Counsel announced in a statement that a national bank charter would be significant for the following reasons: (i) it would put Anchorage on par with other national banks from a regulator perspective, making it easier for traditional banks….Read More
DEBT BUYER SETTLES ENFORCEMENT ACTION REGARDING UNLICENSED ACTIVITIES
The Consumer Financial Protection Bureau (“CFPB”) has entered into a consent order with a debt buyer to resolve allegations that the debt buyer violated the federal Fair Debt Collection Practices Act (“FDCPA”) and Section 1031 of the Consumer Financial Protection Act (“CFPA”) by sending demand letters and filing collection lawsuits through law firms without the proper licenses in ….Read More
NEW YORK LEGISLATURE FINALLY DELIVERS COMMERCIAL FINANCING DISCLOSURE BILL TO GOVERNOR
On December 11, 2020, the New York legislature finally delivered a bill that, similar to California, requires that specific disclosures be provided in certain commercial financing transactions. The New York bill is strikingly similar to, but does differ from, the California commercial disclosure bill as the New York bill….Read More
FOURTH SET OF MODIFICATIONS RELEASED FOR CA-CCPA REGULATIONS
On December 10, 2020, the California Attorney General’s Office released a fourth set of proposed modifications made to the regulations regarding the California Consumer Privacy Act (“CCPA”). These modifications build upon the third draft set of modifications issued on October 12, 2020….Read More