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The FTC report on how big data interacts with the law
March 2016 , E-Commerce Law and Policy
April 24, 2017, Covington Alert
On April 19, 2017, the House Financial Services Committee (the “Committee”) released a new “discussion draft” of the Financial CHOICE Act, its comprehensive regulatory reform bill (“CHOICE Act 2.0”). The Committee released the first version of the bill (“CHOICE Act 1.0”) in June 2016.
March 6, 2017, Covington Alert
Following up on the Consumer Financial Protection Bureau’s (the “Bureau,” or “CFPB”) monthly complaint report highlighting credit reporting issues (and particularly issues with accuracy and disputes), on March 2, 2017, the CFPB issued a special edition of its Supervisory Highlights bulletin focusing on consumer reporting issues, highlighting those same concerns. Director Cordray also issued remarks relating to these issues the same day during the Bureau’s Community Advisory Board meeting. The Bureau sees that it has a unique role to play, as the only federal regulator that can supervise the credit reporting market from end-to-end, and believes that its involvement has brought about substantial changes over the last five years. Now, the Bureau is placing a renewed emphasis on accuracy and dispute resolution in the credit reporting space that deserves the industry’s attention and focus.
July 28, 2016, Covington Alert
Today, the Consumer Financial Protection Bureau (“CFPB”) issued its outline of proposals under consideration for a debt collection rulemaking that would govern third-party debt collection activities of debt collection agencies, debt buyers, collection law firms, and loan servicers. Release of this outline of proposals signals the start of the Small Business Regulatory Enforcement Fairness Act (“SBREFA”) process. Under the SBREFA process, the CFPB must hold a Small Business Review Panel to discuss this outline of proposals and consider the potential impacts on small business entities before issuing a proposed rule. In other contexts, such as the CFPB’s proposed payday and small dollar lending rule, more than one year elapsed between the Small Business Review Panel and the issuance of a proposed rule.