The Federal Deposit Insurance Corporation (FDIC) today released a list of orders of administrative enforcement actions taken against banks and individuals in October 2024. There are no administrative hearings scheduled for December 2024. The FDIC issued five orders. The administrative enforcement actions in those orders consisted of one consent order, one order terminating consent order, two orders to pay civil money penalties (CMPs), and one combined order of prohibition and order for restitution.
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.
On November 6, the Appellate Court of Maryland reversed a lower court’s dismissal of a class action lawsuit alleging violations of the Maryland Consumer Debt Collection Act (MCDCA) and the Maryland Consumer Protection Act (MCPA). The plaintiffs, a class of two individuals, claimed debt collectors filed lawsuits to collect money they knew was not owed, constituting unfair and deceptive practices under Maryland law. The lower court had ruled that the common law litigation privilege barred these claims, providing immunity to the debt collectors for statements made during proceedings.
On November 13, the Consumer Financial Protection Bureau (CFPB) released a report on matched-pair testing in small business lending, highlighting potential racial discrimination. The study reveals that Black small business owners may face less favorable treatment compared to their white counterparts when seeking credit.
Nebraska Governor Jim Pillen (R) signed the Nebraska Data Privacy Act (or NEDPA) into law in April. NEDPA becomes effective on January 1, 2025 – the same day as similar laws going live in Delaware, Iowa, and New Hampshire. This relatively short period between signature and effective date left little time for impacted companies to prepare; however, Nebraska’s approach to applicability criteria has cast a specifically tailored net focused on businesses selling personal data of Nebraska residents.
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