The New York State Department of Financial Services (DFS) recently released new industry guidance outlining operational measures financial institutions may consider implementing during periods of heightened cybersecurity risk. The guidance highlights growing concerns surrounding increasingly advanced artificial intelligence tools capable of sophisticated cyber operations.
The Colorado Supreme Court has issued a unanimous decision clarifying the documentation requirements debt buyers must meet when filing collection lawsuits under the Colorado Fair Debt Collection Practices Act (CFDCPA). The court held that a debt buyer must attach an assignment or other written documentation that specifically establishes ownership of the consumer’s debt when initiating a collection action. The court also determined that an affidavit cannot be used to replace or remedy missing chain-of-title documentation required by statute.
The National Fair Housing Alliance, Rise Economy, and two fair lending compliance companies (BLDS, LLC, and SolasAI) filed suit in the U.S. District Court for the District of Columbia challenging the CFPB’s Regulation B final rule, which implements the Equal Credit Opportunity Act (ECOA). The case is notable not only for challenging the CFPB’s significant rewrite of longstanding Reg B, but also because these are the first consumer advocacy organizations to sue the CFPB over the final rule.
For collections leaders, the old signs of trouble—like a single missed payment—are being replaced by more deliberate patterns of managing money. Borrowers are moving away from "crisis management" and toward a planned way to resolve what they owe. This shift has a big impact on the relationship between lenders and debt settlement companies.
The federal banking agencies have proposed the most significant overhaul of the CAMELS supervisory rating system in nearly 30 years, signaling a major philosophical shift in bank supervision. The proposal would revise the Uniform Financial Institutions Rating System (“UFIRS”) to place greater emphasis on material financial risks and less emphasis on process-oriented supervisory criticisms.
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