Yesterday, we discussed the constitutional legal challenge against New York City’s recently amended debt collection rules, which were scheduled to go into effect on December 1, 2024. These rules would stringently regulate various debt collection activities by debt collectors operating in the city. Today, the New York City Department of Consumer and Worker Protection (DCWP) announced a delay in the enforcement of these new rules until April 1, 2025.
On October 16, the FTC issued its final amendments to the Negative Option Rule, which now applies to all negative option programs and includes a “click to cancel” provision intended to make it easier for consumers to cancel their enrollment in order to halt continued charges.
Beginning in February 2025, the DFPI will register and regulate debt settlement services, education financing, income-based advances, and student debt relief providers – all to protect California consumers and provide more transparency.
The Office of the Comptroller of the Currency (OCC) is revising its guidelines establishing standards for recovery planning by certain large insured national banks, federal savings associations, and federal branches at 12 CFR 30, appendix E/ The final guidelines are effective on January 1, 2025, with staggered compliance dates.
Today, the Consumer Financial Protection Bureau (CFPB) took action against Apple and Goldman Sachs for customer service breakdowns and misrepresentations that impacted hundreds of thousands of Apple Card users. The CFPB found that Apple failed to send tens of thousands of consumer disputes of Apple Card transactions to Goldman Sachs, and when Apple did send disputes to Goldman Sachs, the bank did not follow numerous federal requirements for investigating the disputes.
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