Missing, shoddy, or even falsified documentation in the consumer credit arena is coming under increased scrutiny, as mortgage lenders and servicers are being called to task by borrowers and investors on the issue.

Ballard Spahr's consumer financial services partner Christopher Willis stated, "This thing is just getting started. It's still in its infancy." He predicted more action by the FTC on documentation problems on non-mortgage debt, as well as more focus on the part of state attorneys general and the Consumer Financial Protection Bureau. He suggested that debt collectors and creditors view this as an opportunity to address problems up front. "It's not too late to assess where you are and see where the risks are," he said.

Related Practices

Bank Regulation and Supervision
Consumer Financial Services