Mortgage Banking Update - September 1, 2022
In This Issue:
- We Proudly Welcome Regulatory Compliance Counsel Abigail Pressler to Our Consumer Financial Services Group
- Text Messages From Debt Collectors? Not In My Backyard!
- Director Chopra Discusses Digital Marketing in Remarks at National Association of Attorneys General Presidential Summit
- HUD Announces Unique Entity Identifier Requirement for FHA Lenders
- AFSA and Several Other Trade Associations Urge Second Circuit to Reject CFPB’s Expanded Interpretation of FCRA Reasonable Procedures for Maximum Accuracy Requirement
- This Week’s Podcast Episode: Regulatory and Economic Challenges Currently Facing Banks: An In-Depth Conversation With Keith Noreika, Executive Vice President and Chairman of Patomak Global Partners’ Banking Supervision and Regulation Group, and Former Acting Comptroller of the Currency
- CFPB on Track to Issue Section 1071 Final Rule by March 31, 2023
- Banking Trade Groups Challenge CFPB’s Authority to Regulate Customer Service
- D.C. Department Of Insurance, Securities and Banking Issues Bulletin on Money Transmission
- Did You Know? State Work From Home Update
- Looking Ahead
For the latest updates on the COVID-19 pandemic visit the Ballard Spahr COVID-19 Resource Center
It is my pleasure to introduce the newest member of our growing Consumer Financial Services Group: Abigail Pressler. Abigail is one of the leading lawyers in the country who focus their practice on compliance with the laws that pertain to consumer debt collection. Abigail counsels creditors, third-party debt collectors and debt buyers with respect to the vast array of federal and state laws that cover consumer debt collection. You will be hearing often from Abigail on our blog, webinars and podcast show. Her vast in-house experience at one of the largest debt collectors and buyers will now benefit the clients of our Consumer Financial Services Group.
Some people just don’t like change. New developments are often opposed by small groups prioritizing their own self-interest over the interests of the community at large. In real estate, these groups are sometimes known as “NIMBYs,” short for their rallying cry: “Not in My Backyard!” Well, it looks like debt collectors may have some NIMBYs of their own.
When the Fair Debt Collection Practices Act (FDCPA) was passed in 1977, the most common ways for debt collectors to reach consumers were through phone calls, letters, and telegrams. It took 44 years for the law to catch up to modern technology, but the CFPB finally did it in 2021 with Regulation F’s guidelines for FDCPA-compliant electronic communications like email and text messages. Here are some of the key takeaways:
- Email, text messages, social media, and other electronic media are valid forms of ‘communication’ under the FDCPA. This includes electronic delivery of the initial validation notice or a response to a request for debt validation (options previously discouraged by case law).
- Regulation F allows emails and text messages to be sent with direct consent given by the consumer to the debt collector and indirect consent passed along by a creditor or previous debt collector who obtained direct consent. While not mandatory, there are suggested procedures for obtaining direct and indirect consent that, if followed, grant safe harbor protection against inadvertent disclosure of the debt to a third party.
- Regulation F’s call frequency limits do not apply to email, text messages, or other electronic communications. However, the FDCPA’s general prohibitions against harassment and contact at inconvenient times still apply, so frequency is still a factor and messages should generally be sent between 8:00am-9:00pm local time for the consumer (rather than late at night or early in the morning in the sender’s time zone).
- Electronic communications must contain all the usual FDCPA and state law disclosures plus specific account information required by Regulation F. The rules vary depending on the type of communication.
- Opt out notices are required in all electronic communications. They must be clear and conspicuous and provide reasonable and simple methods for the consumer to opt out. The CFPB’s Small Entity Compliance Guide suggests using a hyperlink or allowing the consumer to reply with words like “stop” or “unsubscribe” to opt out. The Guide also offers sample language such as “Reply STOP to stop texts to this telephone number” or “Click here to opt out of further emails to this email address.” The CFPB left it up to debt collectors to decide where to place the notice. “Although no minimum type size is required, the location and type size must be readily noticeable and legible to consumers.”
This long-overdue update was hardly revolutionary; it simply gave debt collectors permission to use the same modes of communication that most businesses use to interact with consumers – options that are increasingly popular with consumers who want to “go green” or enjoy the freedom of doing things “on demand” whenever, wherever, and however they choose.
Now, NIMBY litigators, legislators, and even private companies are lining up to protest, trying to limit or block debt collectors from using these options even if it’s what the consumer wants.
- Litigators cannot change Regulation F but they can try to make electronic communications more trouble than they’re worth. One of the most popular claims is that the opt out notice is not “clear and conspicuous” and fails to provide a “reasonable and simple method” for the consumer to opt out. These arguments can be made in any situation. For example, compare these two complaints filed by the same attorney making the same arguments about two very different emails:
- Hoskins complaint was based on this opt out notice at the bottom of the email: “Unsubscribe.”
- Green complaint was based on this opt out notice near the middle of the email: “Click here to opt out of further emails for this account.”
Two very different emails, two very similar complaints. Yet it’s difficult to see why these emails are a problem. Both notices are consistent with the CFPB’s guidance (outlined above). They also look just like the opt out/unsubscribe links consumers are used to seeing in emails from their favorite retail stores, social media platforms, banks, and other services.
Federal and state legislators have introduced bills imposing more restrictions:
- US HR 8334 would broaden the scope of the Telephone Consumer Protection Act (TCPA) to prohibit calls and text messages from an automatic telephone dialing system (ATDS) without the prior express consent of the “recipient.” The bigger concern is how they’ve redefined ATDS as “equipment which has the capacity to store or produce telephone numbers to be called or sent a text message” without limiting it to equipment that uses “a random or sequential number generator.” While the bill does direct the FCC to pass a rule clarifying definitions, the removal of that language could reopen the floodgates of litigation for anyone (not just debt collectors) using dialing or texting platforms not currently covered by the TCPA. This bill was introduced on July 12, 2022 and remains pending committee review.
- NY SB 3121 would create a debt collection license requirement and new regulations. While it largely tracks the FDCPA, it deviates in requiring debt collectors to obtain “prior written or recorded and revocable consent of the consumer debtor given directly to the debt collector” before using electronic communications such as email or text message. This bill was reintroduced and referred to a committee on January 5, 2022 where it remains pending.
- DC CB 24-0357 is the latest move by the DC Council to restrict collection activity by debt collectors, debt buyers, and even original creditors. It would prohibit electronic communications before sending the initial notice (meaning those notices must be sent by post), require prior express consent directly from the consumer, and limit debt collectors to a total of 5 electronic communications (emails, text, etc.) per 7 days. The bill was signed by the Mayor on July 7, 2022 and transmitted to Congress where it remains pending review. Unless Congress objects, it will become law and take effect on January 1, 2023.
T-Mobile and Twilio have added third party debt collection to their lists of forbidden message categories, effectively blocking debt collectors from using their platforms to communicate with consumers without any consideration for consumers’ preferences.
Creditors and servicers should pay attention because these same rules may also apply to you! In addition to the TCPA and DC law mentioned above, other states – like California and Maryland – already have laws that require creditors and servicers to comply with the FDCPA (and Regulation F) even if they are passively accepting payments on pre-default debt.
Such policies may be based on good-intentions but they have the potential to do real harm by taking away choices that would actually improve accessibility. Some consumers may prefer phone calls and letters, but that doesn’t work for everyone. For example, phone calls and letters may be embarrassing for people with families or roommates. Some people do not have their own phone but they can check their email at a public library. Others may miss letters because they have unstable living arrangements, travel frequently, or have multiple addresses because they’re a seasonal resident (aka “snow bird”). Email and text messages would allow all of them to stay informed no matter where they go. These consumers have the same rights and deserve the same quality of service as everyone else.
Many consumers have developed a taste for on-demand services that adapt to their preferences and behavior. While most industries have evolved, debt collectors have been held back by rules that are increasingly out-of-touch with society’s expectations for user-friendly experiences. In fact, electronic communications like email and text are particularly convenient ways for businesses and consumers to interact quickly, quietly, and on-demand. Many consumers prefer these options to the disruption of a ringing phone or the delay of exchanging letters by mail. Electronic communications are generally more private and respectful of a consumer’s valuable time. They deliver the same important information in a concise format that’s easy to retain for future review with a continuous history of conversations saved all-together in one place. The ability to share hyperlinks, images, audio, video, and attachments can also help streamline services for faster results.
Most importantly: If a consumer does not like these options, it’s incredibly easy to opt out!
In the end, it all comes down to giving consumers the freedom to make their own choices about when, where, and how they want to communicate with debt collectors – even if it’s sending an email or text message from the privacy and comfort of their own backyard.
On August 10, 2022, Director Rohit Chopra delivered remarks at the 2022 National Association of Attorneys General Presidential Summit in Des Moines, Iowa on the topic of consumer protection in the digital world. Director Chopra focused his remarks on the current state of digital marketing and advertising in an ever-increasing digitalized world.
Director Chopra began his remarks by discussing the shift in advertising by companies from the traditional methods of purchasing time or space in newspapers and on radio or television to the more targeted manner of digital advertising. With this digital advertising, digital sales force teams “armed with personalized and detailed dossiers on each consumer” deliver advertisements personalized to the consumer based upon a “psychographic profile developed on each individual user through surveillance across devices and services accessed across the digital world.” As companies seek to earn money by not only broadcasting the advertising but also by convincing the consumer to click on the advertising, they have become more persistent in using technology to “follow” consumers across the digital world. As a result, Director Chopra noted, “more and more Americans are experiencing the feeling of being digitally stalked by specific ad content.”
Director Chopra highlighted the effect of this personalized digital marketing by addressing former Secretary of Housing and Urban Development Ben Carson’s charges against Facebook for allegedly violating the Fair Housing Act. Secretary Carson had charged Facebook with helping advertisers limit the audience for its advertisements and enabling advertisers to target specific groups of people to the exclusion of protected classes. Secretary Carson alleged Facebook had developed a system that purposefully excluded certain individuals from viewing the same advertisement because the digital profile of the consumer did not match the “composite consumer” determined by Facebook to most likely engage with the ad. As noted by Director Chopra, “Facebook’s ad delivery system prevented advertisers who wanted to reach a broad audience of users from doing so.” Even if an advertiser tried to target an audience that broadly spanned protected class groups, Facebook’s ad delivery system forbid it from doing so.
In speaking to the Attorneys General, Director Chopra reminded them of the role of states to police illegal conduct in consumer financial services and that the Consumer Financial Protection Act “explicitly authorizes states to bring law enforcement actions against covered financial firms and limits the ability for federal preemption abuses to recur.” Noting that the Act exempts some service providers that play absolutely no material role in the offering of a financial product or service, such as service providers that provide ministerial services or who solely provide time or space for an advertisement, other service providers are commingling many other features that go well beyond the exemption. To address this issue, the CFPB has issued an interpretive rule explaining that the service provider exemption for “time or space” will typically not apply to the digital marketing services offered by major platforms, which will make the service providers liable for violations of the Act. He noted that the Act can be enforced by state attorneys general.
Concluding his remarks, Director Chopra stated that advances in technology “should help our economy and society advance, rather than incentivizing a rush to seize our sensitive financial data and to allow tech giants to evade existing laws that other firms must comply with.” Spotlighting the latest initiatives taken by the CFPB to prepare for the future of consumer finance as well as noting future plans, Director Chopra ended his remarks by saying, “As you exercise or look to exercise your authorities under the Act, the CFPB will continue to be a partner in rooting out lawbreakers and keeping markets fair for consumers and honest businesses.”
A complete copy of his remarks can be found here.
In Mortgagee Letter 2022-14, dated August 23, 2022, the U.S. Department of Housing and Urban Development (HUD) announced a Unique Entity Identifier (UEI) requirement for Federal Housing Administration (FHA) lenders and mortgagees, and applicants for FHA approval. The requirement must be implemented no later than December 31, 2022.
Existing FHA lenders and mortgagees under Title I or Title II will need to provide a UEI as part of their institution data in the Lender Electronic Assessment Portal (LEAP), and applicants for FHA approval under such Titles will need to provide a UEI in their application.
In the Mortgagee Letter, HUD explains that the “General Services Administration (GSA) has announced that all entities currently conducting or seeking to do business with the federal government must have a UEI registered in GSA’s System of Award Management (SAM.gov). The UEI is an alpha-numeric identifier used by federal government agencies to maintain consistent name and address data about non-federal entities doing business with the government.”
The Mortgagee Letter contains a link to a government website for entities to obtain more information on UEIs and to register for a UEI.
HUD will accept feedback on the new requirement for 30 days from the date of the Mortgagee Letter
Earlier this year, the CFPB and the FTC filed an amicus brief in an appeal to the Second Circuit, arguing that the Court should reject the District Court’s “unduly narrow” interpretation of the FCRA requirement that consumer reporting agencies (CRAs) follow reasonable procedures to assure accuracy of information included in consumer reports. The CFPB and FTC argue that the FCRA does not distinguish between “legal” and “factual” inaccuracies, and thus CRAs may be held liable for failing to maintain reasonable procedures to prevent even inaccuracies that turn on legal questions regarding the underlying debt or credit information.
Recently, the Chamber of Commerce of the United States of America, America Bankers Association (ABA), National Association of Federally-Insured Credit Unions (NAFCU), Independent Community Bankers of America (ICBA), American Financial Services Association (AFSA), Credit Union National Association (CUNA), and Consumer Bankers Association (CBA) together submitted its own amicus brief in Sessa v. TransUnion asking the Second Circuit to reject the CFPB’s theory, which would require credit reporting agencies and furnishers to adjudicate legal disputes that courts should resolve.
In Sessa v. Trans Union, LLC, Plaintiff-Appellant brought a putative class action alleging that TransUnion reported she owed a “balloon payment” on a vehicle lease, but then inaccurately reported the amount owed as the vehicle’s residual value, which was an optional amount to purchase the vehicle at the end of the lease and greater than the actual amount owed.
The District Court for the Southern District of New York granted summary judgment to TransUnion holding that Plaintiff failed to make the “threshold showing” of inaccuracy on the consumer report. First, the court drew a distinction between factual and legal inaccuracies and held that a CRA cannot be held liable when the issue requires a legal determination as to the validity of the debt the agency reported. In the court’s view, whether Plaintiff in fact owed a balloon payment at the end of the lease was a “legal dispute” that requires “a legal interpretation of the loan’s term.” Second, the court concluded that the information in the credit report was factually accurate because TransUnion reported the exact information it received from the data furnisher.
AFSA and the organizations agree with this decision, noting that it accords with the FCRA’s text, purpose, structure and history. The amicus brief argues that the FCRA requires credit reporting agencies to guard against factual inaccuracies, not to resolve legal disputes. The approach under CFPB’s expanded interpretation would have damaging economic consequences for consumers, furnishers, and credit reporting agencies. ASFA urges that, such a holding is consistent with findings in other circuits recognizing that the FCRA focuses on factual inaccuracies.
In arguing in support of the District Court’s decision, the brief notes that distinguishing between fact and law is a routine task for courts of appeals. Even in cases involving mixed questions of law and fact, the principles of distinguishing legal and factual matters are well established in the courts. ASFA states that the point is not that the analysis is easy per se as there will be hard questions, but rather the point is that the distinction is firmly embedded in the American legal tradition and is familiar to every federal court in the country. The elimination of the accepted fact-law distinction would prove unworkable, expensive, and inefficient in practice.
This Week’s Podcast Episode: Regulatory and Economic Challenges Currently Facing Banks: An In-Depth Conversation With Keith Noreika, Executive Vice President and Chairman of Patomak Global Partners’ Banking Supervision and Regulation Group, and Former Acting Comptroller of the Currency
In our discussion of regulatory challenges, we consider the continuing impact of “true lender” challenges on bank-nonbank partnerships, how regulators approach industry innovation, and whether regulators should face stronger challenges from industry (including what the SCOTUS EPA decision could mean for such challenges). In our discussion of economic challenges, we consider the impact of inflation and recession fears on bank activity. Other topics include the role of bank mergers in the marketplace for banking services and issues faced by regulators in addressing crypto assets.
Alan Kaplinsky, Ballard Spahr Senior Counsel, hosts the conversation.
To listen to the episode, click here.
The CFPB filed its tenth status report with the California federal district court hearing the lawsuit brought to force the CFPB to move forward with rulemaking to implement the small business data requirements of Section 1071 of the Dodd-Frank Act. The Bureau states in the status report that it is on track to issue the Section 1071 final rule by March 31, 2023.
The CFPB agreed to the March 31, 2023 deadline for issuing a final rule in a stipulation with the plaintiffs that was approved by the court last month. The Bureau issued a notice of proposed rulemaking in August 2021 and the comment period ended on January 6, 2022.
In response to the CFPB’s Request for Information Regarding Relationship Banking and Customer Service (RFI), three leading banking trade groups have submitted a comment letter in which they challenge the CFPB’s legal authority for the RFI. The three groups are the Consumer Bankers Association, the Bank Policy Institute, and the American Bankers Association.
In issuing the RFI, the CFPB relied on Section 1034(c) of the Consumer Financial Protection Act which requires depository institutions subject to CFPB supervision (i.e. those with more than $10 billion in assets) to provide “in a timely manner” responses to consumers requests for information about a financial product or service that the consumer obtained from the depository institution. The CFPB described the RFI as an “initiative to improve customer service at big banks.”
The trade groups assert that the right to timely information provided by Section 1034(c ) addresses the right of a consumer to obtain the consumer’s financial data from his or her financial institution. They point out that a bank’s obligation to provide information to a consumer “in a timely manner” in response to a request “is very different from an obligation to serve customers on particular terms or in a certain manner more generally” and that “the latter encompasses a much broader and complex set of interactions between consumers and their financial intuitions, which are not addressed by section 1034.” The trade groups contend that the CFPB is attempting to use the RFI “to create a legal authority that it does not have: the right to dictate the type of customer service banks provide and the manner in which they do so.”
The trade groups also take issue with what they view as the RFI’s implication “that banks’ use of technology to better serve consumers leads to less personal and suboptimal customer service and is a departure from ‘relationship banking.’” They observe that the term “relationship banking” as used in the RFI “seems to refer to reliance on face-to-face interactions and other activities at brick-and-mortar branch locations, as compared with the provision of customer service through telephone, online, or other technologically advanced platforms.” They assert that rather than representing a departure “from the implied personalization of ‘relationship banking,’” banks’ use of “advanced digital technologies such as Artificial Intelligence (AI) and machine learning have accelerated the opportunity for banks to deliver more personalized interactions with consumers through digital channels.”
The trade groups cite to numerous findings and data to refute what they call the CFPB’s “flawed premise that banks provide poor service” and its “inaccurate picture” of the banking industry “as increasingly consolidated, and that such consolidation has degraded customer service.” They note that mergers “can strengthen the ability of banks to achieve economies of scale that allow them to continue to serve communities that have experienced population loss,” thereby enhancing, rather than degrading, customer service.
We have also questioned whether Section 1034(c) is in fact an appropriate tool for the CFPB to use for its apparent purpose of improving customer service. As we previously observed, the CFPB’s invocation of Section 1034(c) as the basis for the RFI is yet another example of the agency’s willingness to attempt to use every tool in its toolbox—whether or not appropriate and regardless of how strained the statutory interpretation–to pursue its priorities.
On August 8, 2022, the District of Columbia Department of Insurance, Securities and Banking (the Department”) issued a Bulletin on money transmission (the “Bulletin”). The Department issued the Bulletin to ensure that parties “engaging in or planning to engage in money transmission with Bitcoin or other virtual currency used as a medium of exchange, method of payment or store of value in the District,” understand that such transactions “require a money transmitter license.”
In support of its position, the Department highlights the July 2020 decision of the U.S. District Court for the District of Columbia in United States v. Larry Dean Harmon, 474 F.Supp.3d 76 (D.D.C. 2020). In Harmon, the court noted that the D.C. Money Transmitters Act of 2000 (“MTA”), D.C. Code §26-1001 et seq., does not define the term “money.” The court therefore relied on the common definition of the term “money,” namely a “medium of exchange, method of payment or store of value.” Finding that Bitcoin was a medium of exchange under this definition, the court determined Bitcoin was ‘money’ for purposes of the MTA.
The court also noted that the MTA specifically defines some specialized banking and financial terms, but the term “money” was left undefined. In the court’s view, this demonstrated a lack of legislative intent for the term “money” to have a specialized definition for purposes of the MTA. As such, the court reasoned that the goal of the MTA is to regulate all kinds of transfers of funds, whether fiat currency, virtual currency or cryptocurrencies.
Treating cryptocurrencies as money, the Department states in the Bulletin that it “views the transactions where entities receive for transmission, store, and/or take custody, of Bitcoin and other virtual currencies from consumers via kiosks (aka BTMs), mobile applications and/or online transactions, as engaging in the business of ‘money transmission.’ Such entities require a money transmitter license to operate in the District.” The Department also states that the application process for a money transmission license is “fact-driven, and whether an entity is considered a money transmitter requiring a license to operate in the District depends on the facts and circumstances of each applicant, including, but not limited to, the applicant’s proposed business plan and proposed flow of funds. Additionally, information about an applicant’s business model may also be required in order to make a determination on whether to grant a money transmitter license.”
Finally, the Department states that it “does not view transactions where entities proposing to sell and buy Bitcoin and other virtual currencies and cryptocurrencies from consumers in exchange for cash payments via kiosks and/or online transactions as engaging in the business of ‘money transmission.’”
On August 26, 2022, the Governor of California approved legislation authorizing remote work under the California Financing Law (CFL) under specified conditions. Among other things, the legislation permits designation by a licensee of an employee, acting within the scope of employment, to perform work on the licensee’s behalf at a “remote location” if the licensee:
- Prohibits in-person consumer interactions, including the physical receipt of cash or other monetary value or the disbursement of loan proceeds, at a remote location and does not designate a remote location to the public as a business location;
- Prohibits records required pursuant to Section 22156 from being physically mailed to, shipped to, or stored at a remote location except for storage on an encrypted device or encrypted media;
- Prohibits the physical receipt of mail related to the licensee’s licensed business at a remote location;
- Prohibits a consumer’s personal information from being physically stored at a remote location except for storage on an “encrypted” device or “encrypted” media;
- Provides an employee working at a remote location with appropriate equipment, which may include encrypted devices, virtual private networks, and similar technology, to perform work and safeguard licensee records and consumer personal information;
- Adopts and adheres to appropriate, as determined by the department, written policies and procedures to supervise and maintain appropriate control over the work of employees at remote locations and safeguard the licensee’s records and consumer personal information in connection with work at a remote location, including, but not limited to, all of the following elements:
- Employee data security training
- Maintenance of security logs of remote logins
- Procedures designed to detect suspicious logins or attempted logins and to suspend access by potentially compromised accounts or equipment
- Data breach response procedures
- Records telephone calls with consumers conducted from a remote location to the same extent as telephone calls with consumers conducted from licensed locations. This paragraph does not require telephone call recording if the licensee does not do so in the normal course of business for the employee or business in question.
- All books, records, and persons that the commissioner is entitled to examine, inspect, or interview shall be made available to the commissioner at a licensed location.
For the purposes of the foregoing, a “remote location” means a personal residence or a temporary, nonpublic location not owned or leased by the licensee or an affiliate of the licensee that is not simultaneously accessible by anyone other than a single employee and individuals who maintain a common household with the employee.
“Encrypted” means rendered unusable, unreadable, or indecipherable to an unauthorized person through a security technology or methodology generally accepted in the field of information security.
Effective September 13, 2022, the Ohio Residential Mortgage Lending Act (“RMLA”) and Consumer Installment Loan Act are amended to authorize remote work under specified conditions. As it pertains to the RMLA, a registrant or entity holding a letter of exemption may allow a mortgage loan originator or any other person associated with the registrant or entity to transact business on behalf of the registrant or entity from a location other than the registrant's or entity's principal office or a branch office if all of the following apply:
- The registrant or entity has a written policy governing the supervision of the mortgage loan originator or other person associated with the registrant or entity while the originator or person transacts business on behalf of the registrant or entity from such a location;
- Access to the registrant's or entity's platform and customer information is in accordance with the registrant's or entity's written information security plan;
- The mortgage loan originator or other person associated with the registrant or entity does not interact with a customer at the originator's or person's residence, unless the residence is the registrant's or entity's principal office or a branch office; and
- Physical records are not maintained at such a location.
The superintendent of financial institutions may charge a registrant or entity an annual fee to cover the costs associated with administering the foregoing provision. The fee shall not exceed $25 for each location at which a mortgage loan originator or any other person associated with the registrant or entity transacts business on behalf of the registrant or entity other than the registrant's or entity's principal office or a branch office.
Arlington, VA | September 8-9, 2022
Legal Session #1: Work in the Current Economic and Mortgage Market Environment
Speaker: Meredith S. Dante
Legal Session #3: Other Top Legal Issues That HR Managers at Mortgage Companies Should Know About
Speaker: Richard Andreano
Washington, DC | September 18-20, 2022
Speaker: Michael Gordon
Speaker: Richard Andreano
Speaker: Stacey L. Valerio
Speaker: John D. Socknat
Speaker: Richard Andreano
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