Loop Consulting

12/23/2013

CFPB Advanced Notice of Proposed Rulemaking (ANPR) for the debt collection industry has received 1,000 comments in the first 30 days

On November 6, 2013 the Consumer Financial Protection Bureau (CFPB) began soliciting input from consumers and debt collection participants for their desired changes to debt collection regulations. The ANPR is open for comments for 90 days. Within the first 30 days, over 1,000 comments have been submitted.

Loop Consulting urges all consumers, clients and partners to participate in this unprecedented opportunity to have their voice heard. Comments may be submitted via Regulations.gov or RegulationRoom.org. These forums allow for your desires to be communicated directly to the rule making authority, bypassing lobbyists, congress and other traditional roadblocks to voicing your opinion.

The CFPB is the federal government’s premiere advocate for consumer rights and this unique opportunity to participate should not be missed.

12/19/2013

Mississippi AG complaint against JPMorgan Chase keeps industry focused on vendor oversight issues.

With the Attorney General of Mississippi suing megabank JPMorgan Chase alleging 18 types of violations that demonstrate “egregious” lapses at every stage of JPMorgan Chase’s collection process, the ARM industry headlines continue to carry a focus on vendor oversight issues. Virtually all major banks in the U.S. were challenged keeping up with increasing consumer credit card defaults due to the recession, with many realizing ten-fold increases in default rates over the last several years. That influx of defaulted accounts, compounded with increased merger and acquisition activity over the same period, created serious issues with the integrity of data, inventory, affidavits and judgments.

We at Loop Consulting would like to remind our clients and partners that based on yesterday’s CFPB lawsuit against Cash Call, it seems that the expectation is service providers may have an increasing requirement for due diligence on their clients activities to avoid vicarious liability in future regulatory actions. Contact Loop Consulting in the event you need any guidance or assistance in developing a robust Compliance Management System.

12/18/2013

Shortly after promoting their interest in short term consumer loan practices, on December 16th the Consumer Financial Protection Bureau (CFPB) took its first action against an online loan servicer, its owner, its subsidiary and its affiliate, for collecting money consumers did not owe. In the complaint the CFPB alleges that the defendants violated the Consumer Financial Protection Act’s prohibitions on unfair, deceptive and abusive practices, including illegally debiting consumer checking accounts for loans that were void. The loans made allegedly violated either state licensing requirements or interest rate caps.
To date, Compliance Management Systems have been directed towards a creditor’s oversight and administration of service providers and a service provider’s ability to meet a creditor’s due diligence standards. This new lawsuit may evidence a developing expectation for service providers to conduct appropriate diligence on their clients to avoid being included in regulatory actions brought against an issuer. It seems the CFPB may hold vendors and third party collectors liable for the actions of the creditor and will not only look to upstream vicarious liability, but downstream as well.
Does your Compliance Management System provide the appropriate controls and safeguards? Loop Consulting offers comprehensive compliance expertise and assistance to help mitigate the risk.

11/22/2013

Profit Derived From Consumer Satisfaction

Loop Consulting offers the accounts receivable management industry a broad suite of consultative services focused on the consumer experience.

We provide financial institutions, credit unions, asset purchasers, collection agencies and law firms expert guidance and solutions that encompass compliance, operations, strategy and technology.

Our custom tailored solutions are based on the foundation of mitigating risk to the consumer while improving customer satisfaction, thereby providing endless possibilities for our clients’ growth and revenue potential.

11/22/2013