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MoFo Reenforcement The Enforcement Blog

Tag Archives: Administrative Procedure Act

What You Need to Know Now About the CFPB’s Debt Collection Proposal

Posted in CFPB, Regulatory Developments, UDAAP

On July 28, 2016, the CFPB issued its outline of proposals under consideration for the regulation of debt collection. This 117-page release, entitled “Small Business Review Panel for Debt Collector and Debt Buyer Rulemaking: Outline of Proposals Under Consideration and Alternatives Considered” (“Outline”), was announced in connection with the CFPB’s field hearing on debt collection… Read More

OCC Takes a Page from the CFPB’s Playbook on Overdraft Programs

Posted in CFPB, Regulatory Developments

On February 11, 2015, the Office of the Comptroller of the Currency (OCC) issued an “updated” installment to the Comptroller’s Handbook in a new booklet entitled “Deposit-Related Consumer Credit.” In doing so, the OCC stole a page from the playbook used by the Consumer Financial Protection Bureau (CFPB) in its notice of proposed rulemaking on… Read More