“It’s in the Contract” Is Not an Auditing Method

Relying solely on a contract as a means of oversight is like assuming that having speed limit signs eliminates the need for traffic enforcement. A contract might outline the expectations and responsibilities, but it’s not enough to ensure compliance or effectiveness. In the realm of audits—whether you’re assessing internal operations, third-party vendors, or even a fourth party hired by a third party—simply pointing to contractual clauses is not an adequate […]

Seeing Beyond the Surface: Why Fourth-Party Audits Matter in Debt Collection

As a creditor managing third-party collection vendors, ensuring their compliance and effectiveness is critical to protecting your brand, customers, and bottom line. But have you considered the risks posed by their vendors? These subcontractors, known as fourth parties, often play integral roles in service delivery but can introduce significant risks that ripple through your operations.  In this blog, we explore why auditing fourth-party vendors is essential and provide some practical […]

FCC Receives Mixed Feedback on Proposed AI Communication Rules 

The Federal Communications Commission (FCC) is facing mixed reactions to its proposed rules for regulating artificial intelligence (AI) in communications. The draft rules aim to address potential issues with AI-generated calls while keeping pace with the rapid development of AI technology.  What the Proposed Rules Cover  The FCC’s proposal focuses on outgoing calls that use AI-generated voices, such as voice cloning technology, which has the potential to mislead consumers. However, […]

CFPB Finalizes Rule to Supervise Large Digital Payment App Providers

The Consumer Financial Protection Bureau (CFPB) has finalized a rule to oversee the largest nonbank companies offering digital payment and wallet services. This rule targets companies handling over 50 million transactions annually, ensuring they adhere to federal laws similar to those governing banks, credit unions, and other financial institutions under CFPB supervision. Collectively, the apps covered by this rule process more than 13 billion consumer transactions each year.  Although the […]

Understanding QMB Protections: What Debt Collectors Need to Know 

The Consumer Financial Protection Bureau (CFPB) and the Centers for Medicare & Medicaid Services (CMS) are increasing efforts to protect low-income Medicare beneficiaries from improper medical billing practices. For those working in the debt collection industry, understanding these protections is crucial to ensuring compliance and avoiding potential challenges related to collecting medical debts.  This initiative focuses on the Qualified Medicare Beneficiary (QMB) group, which includes about one in eight Medicare […]

FTC Cracks Down on Georgia-Based Debt Collector for Deceptive Practices 

The Federal Trade Commission (FTC) has taken decisive action against Global Circulation, Inc. (GCI), a Georgia-based debt collection agency, accusing the company of using unlawful tactics to coerce consumers into paying more than $7.6 million in false debts. According to the FTC, GCI and its owner, Kenneth Redon III, misled consumers by making threats of jail time, harassing their family members, and using various other illegal practices to collect bogus […]

Credit Card and Auto Loan Defaults Exceed Pre-Pandemic Levels

The Federal Reserve Bank of New York’s Center for Microeconomic Data released its Quarterly Report on Household Debt and Credit, offering key insights into the state of American debt. Accompanying the report is a Liberty Street Economics blog post that explores trends in debt-to-income ratios and what they reveal about Americans’ ability to manage their debt. The New York Fed’s analysis of delinquency is comprehensive, so rather than reiterate their […]

FTC Announces Virtual Open Meeting on November 14: Public Invited to Participate and Discuss Key Consumer Protection Initiatives 

Federal Trade Commission (FTC) Chair Lina M. Khan has announced a virtual open meeting scheduled for Thursday, November 14, 2024, at 11 a.m. ET. The event will kick off with an opportunity for members of the public to share feedback and address the Commission, with each speaker allotted two minutes to comment on the FTC’s work or raise relevant issues.  The tentative agenda for the November 14 meeting includes:  Older […]

Update on NY Debt Collection Rule Amendments: New Implementation Date of April 1, 2025 

The Department of Consumer and Worker Protection (DCWP) has announced updates to its debt collection regulations, aiming to enhance consumer protections and better align with current practices in the industry. Originally set to take effect on December 1, 2024, these regulations will now be implemented on April 1, 2025. This delay allows additional time for debt collectors to adjust their operations in response to the feedback provided by industry stakeholders.  […]

CFPB Orders VyStar Credit Union, Formerly JAX Navy Federal Credit Union, to Compensate Consumers After Online Banking Debacle

In a recent enforcement action, the Consumer Financial Protection Bureau (CFPB) has held VyStar Credit Union—formerly known as JAX Navy Federal Credit Union—accountable for a disastrous online banking transition that harmed its members. In May 2022, VyStar launched a new virtual banking system that was fraught with technical issues, leaving thousands of members unable to access basic banking services for weeks. Some features remained unavailable for over six months, resulting […]