On Wednesday, July 8, the CFPB announced its latest — and largest — settlement of claims of unfair and deceptive debt collection practices. The OCC and 47 State Attorneys General all were part of the overall settlement. The numbers are significant: $50 million in restitution and $166 million in penalties. The injunctive relief is extensive, with pages and pages of requirements that extend for several years even though the credit card issuer stopped the practices at issue nearly two years ago. Although the alleged UDAAP violations do not plow new ground, the injunctive relief provisions provide a roadmap to debt sellers and debt collectors on what the regulators view as best practices. They also put regulated entities on notice that debt collection remains high on the enforcement agenda.
Read our client alert.