Video

  • 19 minutes

CFPB Bulletin - Credit Card Add-On Products, Consumer Debt Collection and Credit Card Marketing

 
In areas where similar conduct has been found across many companies with the same product or services, the bureau has issued bulletins to provide guidance, or in other words - warnings - to those that are engaging in the conduct. Credit card add-on products have received numerous enforcement actions. While the focus is on credit card add-on products, institutions should take the guidance into consideration when they offer similar products in connection with other forms of credit or deposit services. Experience indicates that some credit card issuers have employed deceptive promotional practices when marketing add-on products. There was also a bulletin (Bulletin 2013-07) released to address acts or practices related to consumer debt collection that can present UDAAP issues.

In this video our speaker, Richard J. Andreano, reviews these bulletins as well as a Bulleting 2014-02 regarding the marketing of credit card promotional APR offers.

Richard J. Andreano is a Partner and practice leader of the mortgage banking group at Ballard Spahr LLP. He is a Fellow with the American College of Consumer Financial Services Lawyers. Mr. Andreano counsel clients on residential mortgage regulatory matters, including ability to repay, TILA/RESPA integrated disclosure (TRID) rule, CFPB supervision and examination, UDAAP and other Dodd-Frank matters.
Runtime: 19 minutes

Agenda

Faculty

Richard J. Andreano

Richard J. Andreano

Ballard Spahr LLP

  • Partner at Ballard Spahr LLP
  • Practice leader, Mortgage Banking Group, Ballard Spahr LLP
  • Fellow, American College of Consumer Financial Services Lawyers
  • Chambers USA: America's Leading Lawyers for business, banking and finance: financial services regulation: consumer finance (compliance), national ranking, 2014 to 2017
  • Wrote MBA Compliance Essentials Loan Originator Compensation Resource Guide™, published by the Mortgage Bankers Association
  • Co-wrote, MBA Compliance Essentials TILA/RESPA Integrated Disclosure TRID Rule Resource Guide™, published by the Mortgage Bankers Association
  • Editor-in-chief, Mortgage Finance Regulation Answer Book 2011-2012, published by the Practising Law Institute; author of chapters on the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Home Mortgage Disclosure Act, and the Real Estate Settlement Procedures Act; and co-author of the Equal Credit Opportunity Act and Truth in Lending Act chapters
  • Counsels clients on residential mortgage regulatory matters, including ability to repay, TILA/RESPA integrated disclosure (TRID) rule, CFPB and other regulator supervision and examination, UDAAP and other Dodd-Frank matters
  • Frequent speaker and author on mortgage industry issues
  • Can be contacted at 202-661-2271 or [email protected]

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