Are Robo Dialers Worth the Risk?

It’s worth reading this Op-ed on American Banker titled, “Real issue for debt collectors is the irrelevance of telephones

Is it worth the risk?

“TCPA litigation increased 31.8% from 2015 to 2016 while Fair Debt Collection Practices Act litigation decreased during the same time period.”

Does it work?

“Phone calls are losing relevance as consumers migrate to communicating with companies over digital channels. Indeed, the tech company Neustar reports that 97% of business calls go unanswered.”

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Ohio bill takes aim at CSO model

HB 123 is floating around.  It’s unlikely that in it’s current form it could pass.  House Bill 123 would allow short-term lenders to charge a 28 percent interest rate plus a monthly 5 percent fee on the first $400 loaned — a $20 maximum rate. Required monthly payments could not exceed 5 percent of a borrower’s gross monthly income.

Speaker Pro Tem Kirk Schuring is recommending these changes.

  • Refusing a new loan if a borrower has an active loan
  • Requiring a three-day waiting period before taking a new loan
  • Allowing a three-day right-to-rescind a loan
  • Creating a payment plan through interest free payments

It’s hard to say what will happen.  A group is trying to get this on the ballot as a way to get around the legislative process.  This rarely works out for lenders because it’s people throwing their opinion around when it does not affect them.

You can read more in the Columbus Dispatch, “As Ohio payday lending law fails, some lawmakers ready for new regulations.”

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So what’s up with the CFPB?

It’s clear that the CFPB is taking a new direction, but what can we expect.  This article titled “THE CFPB UNDER NEW LEADERSHIP: WHAT TO EXPECT IN 2018” is a good read.  Let’s hope the CFPB’s Robinhood past goes away.

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Richard Cordray and the Inside Scoop

Alan Kaplinsky wrote a great article titled What the D.C. Circuit decision vacating stay of EPA rule could mean for final CFPB arbitration and payday loan rules.  What is helpful is the inside scoop on Richard Cordray:

Director Cordray will leave the CFPB in the fourth quarter of this year to run for Ohio governor.

Essentially, he’s going to push the arbitration and payday rules out, but will be out of his position before they go into effect.  Essentially, he’s grandstanding on two rules that will never see the light of day b/c the new director will be appointed by President Trump and will shelve them.  This is a good strategy for Cordray, but it’s also a poor use of tax payer dollars given the situation.  It’s the equivalent of loafing it at your current job while you try to find a new one.  The problem is that he’s been loafing it for a few years now.

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Is the CFPB in trouble? It’s eerily quiet.

 

I enjoyed a speculative article in Market Watch on Richard Cordray.  Is Cordray a sitting duck until after Ohio elects a new governor?  Seems far fetched, but it is juicy.  John Kasich can not run again to term limits in Ohio law.  Like Kasich, but kudos to Ohio for creating term limits.  We need more term limits.

“Despite several calls by House Republicans for President Donald Trump to fire Consumer Financial Protection Bureau Director Richard Cordray, the president could decide to keep his friends close and his enemies closer.”

Last week, USA Today chimed in with “Changes loom for America’s consumer watchdog”  President Trumps executive order on the core principals for regulating the United States financial system never mentions the CFPB.  If you have not read the executive order, you should. It’s good stuff.

It would be terrible if the CFPB had to die a long and painful demise b/c of a lack of funding 🙂

 

 

 

 

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Hudson Cook Analysis on Fintech National Charter

This would be UUGE!  You can see the full article HERE.

“The OCC proposal, eagerly awaited by online lenders and participants in marketplace lending platforms, outlines a way for such entities to enjoy the same preemption authority of national banks over various state licensing, usury, and disclosure requirements.”

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Advance America and CFSA seeking injunction relief

“Advance America said its own situation became dire after five banks decided in the last month to cut ties, including a 14-year relationship with U.S. Bancorp, putting it “on the verge” of being unable even to hold a bank account.”

You can read the full article HERE.

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CFPB Webinar – Ballard Spahr

Ballard Spahr is hosting a webinar to discuss the proposed rules titled: “The CFPB’s Proposed Payday/Auto Title/High-Rate Installment Loan Rule: Can Industry Adapt to the New World Order?

You can register HERE on their website.

A Ballard Spahr webinar on June 15, 2016
12:00 PM – 1:00 PM ET

From their website, the topics:

The companies and products covered by the proposal.
The proposal’s limitations and requirements for covered products.
The proposal’s impact on the industry The differences between the proposal and last year’s SBREFA outline.

I also highly recommend signing up for their blog at CFPB Monitor…extremely helpful.

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Google Adwords shutting out payday lenders

You can read the article at the Washington Post titled “Google to ban payday loan advertisements.”

Additionally, David Graff, Google’s director of global product policy:

“We’re banning ads for payday loans and some related products from our ads systems. We will no longer allow ads for loans where repayment is due within 60 days of the date of issue. In the U.S., we are also banning ads for loans with an APR of 36% or higher.”

It’s important to note that the organic search results will still exist.  What I’m wondering is if Google was pressured by the CFPB or they just decided to do this??

If your curious, you can see other industries and practices that Google bans on their website HERE

The explicit list consists of:

  • Adult oriented content: porn, dating services, sexually suggestive content
  • Alcohol
  • Gambling
  • Prescription drugs and healthcare related products
  • Weapons

 

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Are Arbitration Agreements Done?

Hudson Cook broke the news that the CFPB Proposes Rule Prohibiting Mandatory Arbitration Clauses.

I can see the vultures swarming.

 

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