In its consent order with ACE Cash Express, the CFPB ordered ACE to pay $5 million in restitution and $5 million in civil penalties for alleged collection misconduct. The alleged violations appear at first blush to be largely garden-variety in nature and an independent Deloitte study commissioned by ACE found that roughly 4 percent of randomly sampled collection calls involved collector errors. CFPB enforcement staff dismissed the Deloitte study for unidentified "serious flaws" and the CFPB press release and prepared comments by Director Cordray charged ACE with using its debt collections to trap borrowers in a “cycle of debt.”

So what is going on here? In this webinar, we will discuss the implications of the ACE consent order for first-party and third-party debt collectors and for payday lenders.

Topics

  • Has the CFPB set a new bar for debt collectors? Is compliance possible?
  • How can collectors stay out of trouble with the CFPB? 
  • What does the consent order say about how the CFPB views restitution? Civil money penalties? What does it say about CFPB concerns about sustained use of high-cost credit?  

Program

12:00 PM - 1:00 PM ET | Webinar

Moderator

Alan S. Kaplinsky, Practice Leader
Consumer Financial Services Group

Presenters

Jeremy T. Rosenblum, Practice Leader
Consumer Financial Services Group

Christopher J. Willis 
Consumer Financial Services Group

Kim Phan
Consumer Financial Services Group

This program is open to Ballard Spahr clients and members of the financial services industry. There is no cost to attend. This program is not eligible for continuing education credits.

Please register at least two days before the webinar. Login details will be sent to all approved registrants. For more information, contact Lisa Prickril at prickrill@ballardspahr.com.

Related Practice

Consumer Financial Services