Archives for July 2020

A court decision out of the Western District of Washington (W.D. Wash.) came out on Friday that discusses the balance between the credit reporting and the Fair Debt Collection Practices Act’s (FDCPA) bona fide error defense. The case is Burr v. Evergreen Prof’l Recoveries, Inc. and the key takeaway is to audit what you report.

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What Happened?

This case arises out of plaintiff’s medical debt, which was broken up into a group of several accounts. At some point, defendant sued plaintiff to collect on this debt. The parties settled the collection lawsuit, and defendant now agrees that the underlying debts are no longer owed.

The problem occurred when plaintiff reviewed her credit report and saw that defendant continued to negatively report on two of the accounts. Plaintiff sent a letter to defendant demanding that they delete the entries, which defendant did. However, defendant then erroneously re-reported the accounts and continued to do so until plaintiff said she would file an FDCPA lawsuit against them. Defendant again corrected the reporting, and plaintiff filed the lawsuit in question.

The Court’s Decision

The court quickly concluded that an FDCPA violation occurred based on defendant’s own admission to the errors. The court then turned to the question of whether defendant was entitled to the bona fide error defense, and summarily decided the answer was “no.”

The court’s reasoning turned primarily on the requirement for defendant, if it seeks to assert the bona fide error defense, to have maintained procedures reasonably adapted to avoid the violation. The court found:

The Court has reviewed the briefing of the parties and the declaration of Evergreen president Monica Severtsen and finds there is no evidence for a reasonable juror to conclude that Evergreen maintained a specific procedure adapted to avoid the initial reporting error. Instead, there is only evidence that Evergreen has a system of coding accounts as disputed or paid off. There is no evidence that Evergreen has procedures to double check coding before it is implemented, or to audit the coding after it has been completed.

With that, the court granted summary judgment in favor of plaintiff on the FDCPA claim.

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New York, N.Y. — The Office of Inspector General (OIG) of the United States Department of Health and Human Services (HHS) has issued a favorable decision – Advisory Opinion #20-04 – in response to a request filed by RIP Medical Debt (RIP), a national nonprofit. The request was for the OIG to review a proposed expansion of RIP’s mission-driven medical debt forgiveness program.

The OIG’s Advisory Opinion states it will not impose sanctions under federal anti-kickback or civil monetary penalty laws when RIP works with health systems and large physician groups that donate or sell certain unpaid patient accounts (i.e., bad debts) to RIP. After acquiring an account, RIP abolishes the patient’s financial liability and rehabilitates their credit score.  

“We are excited by this development and look forward to growing our ability to provide economic relief to even more families through the removal of medical debt,” says RIP’s Executive Director, Allison Sesso. “Through this transformative opinion, hospitals and health systems can now expand their healing reach to include their patients’ financial health – a known determinant of physical and mental wellbeing.” 

RIP is a national 501(c)(3) organization founded in 2014 for the sole purpose of eliminating the medical debt burdens of low-income individuals with limited capacity to pay their medical bills. The model leverages even small donations from people across the country to abolish outstanding medical debts. To date, RIP has purchased medical debt accounts only from commercial debt buyers on the secondary debt market. These debts originated from hospitals and physician groups which sell their accounts receivable to commercial debt buyers. RIP acquires, and then forgives, these debts.  

RIP provides relief to individuals with incomes at or below two times the federal poverty level, whose medical debts are five percent or more of their gross annual incomes or who are insolvent. (Individuals cannot apply to have their debts abolished.) Until now, RIP has acquired delinquent accounts that meet these criteria for relief only when those debts have been available on the secondary debt market.  

Now that the OIG has issued Advisory Opinion #20-04, RIP Medical Debt will begin obtaining debt directly from health systems and large physician groups, vastly expanding the number of families benefiting from the work of RIP. Over the next several months, RIP will ramp up its direct engagement with providers. To inquire about working with RIP Medical Debt as a hospital, health system or independent physician’s group with more than 50 members, please contact RIP’s Director of Debt Acquisition & Relief, Mike Toth at mtoth@ripmedicaldebt.org or 832-717-2879. 

“Partnering directly with providers – especially health systems and hospitals – allows RIP to help resource-challenged individuals sooner than we can now. Our vision of removing hardship for the highest number of people is now in sight,” says Craig Antico, RIP’s co-founder and Director of Debt Operations. “I’m grateful the OIG sees our value and is giving their green light for hospitals and physicians to donate or sell debts owed by the poor and those in hardship directly to RIP.”  

The massive and growing problem of medical debt in America, and RIP’s charitable efforts, were most publicly highlighted on an episode of John Oliver’s HBO show Last Week Tonight when the late-night host worked with RIP to eradicate $15 Million of medical debt. The nonprofit has also collaborated with numerous pro-athletes, WeTransfer, NBC Universal and many others. Its work has been covered by Good Morning America, The New York Times, Associated Press, CNN, Fox News and many other outlets.  

“We believe the Advisory Opinion will provide an important measure of comfort to hospitals and health systems and large group practices,” says RIP Board Member and Nixon Peabody Partner Michele Masucci. “Now they can donate their qualifying medical debts to RIP consistent with compliance considerations and it will clear the path to creating a positive impact on patients challenged by current health care conditions.” 

Medical debt causes wide-ranging damage, from preventing people from seeking the care they need and filling their prescriptions to blocking access to jobs, housing and loans when employers, landlords and banks check credit ratings.   

About RIP Medical Debt

Since being founded in 2014 by two former debt collectors, RIP Medical Debt has acquired, and abolished, more than $2.5 billion of oppressive medical debt, helping over 1.5 million individuals get out from under the burden of crushing medical debt. On average, one dollar donated to RIP forgives $100 of medical debt, empowering every donor to have an outsized impact. To learn more, visit https://ripmedicaldebt.org/ or reach out to Daniel.

TROY, Mich. — TECH LOCK Inc., a RevSpring Company, today announced its TECH LOCK Secure™ Managed Cybersecurity and Integrated Compliance Services, fulfilling a growing demand for customers struggling with the challenges of keeping pace with modern security threats. TECH LOCK Secure™ is comprised of a comprehensive suite of Managed Security and Compliance Services, including Endpoint Detection and Response, Network/Firewall, Log/SIEM and Vulnerability Management. The service is supported by a U.S. based 24x7x365 Security Operations Center (SOC) providing quick response to security events through the TECH LOCK Secure™ service portal, powered by a cloud-based machine learning engine enabling security event orchestration, detection and response.

TECH LOCK recognized that businesses were spending on compliance basics but were falling behind in what was needed to keep their business and customer data safe against hackers. TECH LOCK Secure™ is designed to address this concern and meet the demands of businesses that have limited budgets, so they do not have to focus on security or compliance, but now have a service that addresses both. “We wanted to make it easy and accessible for any company to obtain best-in-breed security technology, operations and orchestrated incident response,” said Brian McManamon, president of TECH LOCK Inc. “Our in-depth knowledge and experience with data compliance standards ensures that our solution provides immediate value to businesses by delivering comprehensive data protection while maintaining continuous compliance.”

TECH LOCK Secure™ is a turn-key solution based on modern, adaptive cybersecurity technologies. Customers have complete transparency to all security and compliance operations. The TECH LOCK Secure™ portal provides real-time dashboards and reports with the ability to drill down into specific data. Through the information provided in the portal, the customer can quickly validate that their organization is secure and up to date with their compliance requirements.

“As a leader in outsourced patient financial services, ensuring patient privacy and protecting the data entrusted to us is critical,” said Jim Warner, chief technology officer, State Collection Service, Inc. As a result, working with TECH LOCK Inc. is not just about checking the box for compliance.” “Security and compliance are so interwoven that subscribing to TECH LOCK Secure™ was an easy choice to make to ensure data security,” said Tim Haag, president, State Collection Service, Inc.

“Our long-term partnership with TECH LOCK provides us with tremendous peace of mind knowing that we are using market-leading technology and processes to ensure data security and patient privacy.”

About TECH LOCK

TECH LOCK enables organizations to navigate, detect, and respond to today’s modern cybersecurity and compliance challenges. Our focus is the delivery of adaptive managed security services and security operations leveraging industry-leading technology enriched with threat intelligence and powered by machine learning in an orchestrated model. We deliver comprehensive security and compliance services with measurable outcomes and personalized support. For more information, visit techlockinc.com.

Jacksonville, Fla. — Rick Regan, Co-Founder, joins Imagined.cloud to head North American sales. Rick’s experience providing enterprise solutions in the ARM and BPO industries strengthens Imagined.cloud executive team. With over twenty years of proven client engagement, Mr. Regan brings the knowledge and understanding necessary to build lasting relationships within the industry. 

Mr. Regan holds a B.A. in Business from The University of Texas at Dallas. Prior to joining Imagined.Cloud, Mr. Regan was a top performing strategic sales advisor for several technology and financial services companies. Carl Harkleroad, the original Founder of Imagined.Cloud, had this to say about Mr. Regan “It is exciting to re-align with Rick and have him head up our sales efforts. His operational management and diverse sales experience will complement our growing team and allow us to accelerate. I am looking forward to replicating our prior success of delivering the best software solutions and service to our customers.”

About Imagined.Cloud

Founded in 2016, Imagined.Cloud is focused on cloud native application development for recovery and business process outsourcing. Established to bridge the gap between traditional business processes and secure cloud architectures. Imagined.Cloud’s first solution, OutSourcer®, provides fluid outsourcing process management with real-time compliance and activity monitoring. For more information or to schedule a demo, visit www.imagined.cloud or call 877.787.0730.

Editor’s note: This article is provided through a partnership between insideARM and Squire Patton Boggs LLP, which provides a steady stream of timely, insightful and entertaining takes on TCPAWorld.com of the ever-evolving, never-a-dull-moment Telephone Consumer Protection Act. Squire Patton Boggs LLP—and all insideARM articles—are protected by copyright. All rights are reserved. 

Here’s a big TCPA ruling for debt collectors and servicers—and a bit of a downer for everyone else.

The Court in Mosley v. General Revenue Corp., No. 1:20-cv-01012- (C.D. Ill. July 20, 2020) granted a defendant debt collector’s motion to dismiss a TCPA claim at the pleadings stage, reasoning that it is simply not plausible the Defendant used a random or sequential number generator to make the challenged calls. While that’s great news, the ruling contains a bit of a curveball for other callers hoping to leverage Gadelhak at the pleadings stage.

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There is an ongoing split of authority regarding the scope of the TCPA. The Seventh Circuit Court of Appeals—where Mosely was venued—is a particularly favorable jurisdiction for Defendants because the ruling in Gadelhak assures that the TCPA only applies to pre-recorded or random-fired calls. Nonetheless, there is relatively little case law regarding the pleadings standard for post-Gadelhak TCPA cases. As we all know, positive case law is scarcely beneficial if it can’t be used at the pleadings stage to cut these cases off at the knees—if a Defendant is forced to wait until summary judgment for a dismissal on the ATDS issue, hundreds of thousands in fees and expense may already be incurred. (A cost the Defendant is unlikely to recoup).

That’s what makes Mosely so important. The Plaintiff in Mosely admitted—as he had to—that Gadelhak requires the use of a random or sequential number generator to make out a TCPA ATDS claim. However, Plaintiff argued at the pleadings stage that he could not be expected to know how the Defendant’s system operated. Instead, he argued it was enough to allege that he had no relationship with the caller and allege that the system had the capacity to dial randomly or sequentially. 

The Court was unmoved and made a critical finding that everyone should keep in mind out there in TCPAWorld:

The Court rejects the inference that a claim is plausible because a plaintiff merely alleges the dialer system has the capacity to randomly or sequentially generate numbers, without any factual basis for such allegations.

In other words, conclusory allegations of the “capacity” of a system to randomly or sequentially dial, but lacking any supporting facts, are to be properly and summarily dismissed. Nice!

But it gets even better, especially for debt collectors. The Court goes on to look at the context and content of the phone calls and determines that random or sequential number generation is simply not plausible—the calls at issue were debt collection calls and debt collectors do not make random-fired calls. In the Court’s words:

Plaintiff offers no plausible explanation why a debt collection company would need or use a machine which had the capacity to dial or store randomly or sequentially generated numbers.

In the absence of such an explanation, the Court would not allow the claim to move forward and dismissed it.

There is a dark cloud over this sunny day for TCPA defendants, however. The Court does throw some callers under the bus as potential random-dialers:

It is far more likely that a telemarketing company, bank, or other seller of goods would desire to have machines with the capacity to dial randomly or sequentially generated numbers.

That’s a bit of a sucker punch for non-collectors, but hopefully this dicta will not be used to keep marketing callers trapped in TCPA cases longer than necessary.

We’ll keep an eye on all of this for you.

Want to track TCPA trends and important court decisions?
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On June 30th of this year, Colorado quietly tidied up some pieces of legislation and made a change to how collection agencies communicate with consumers.

Per the text of Colorado House Bill 20-1402, starting on 1 July 2020, agencies collecting debt from Colorado consumers need to update the language on the first notice sent.

Before 30 June 2020, collection agencies collecting in Colorado were required to inform consumers of their rights under the Colorado Fair Debt Colletion Practices Act. The language Colorado expected to see was this:

FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE WWW.AGO.STATE.CO.US/CADC/CADCMAIN.CFM

If you weren’t able to fit that language on the first page of your notice, Colorado required language on the front notifying consumers to see the back of the letter for info about the CFDCPA.

That has changed.

Your letters now need to say:

FOR INFORMATION ABOUT THE COLORADO FAIR DEBT COLLECTION PRACTICES ACT, SEE HTTPS://COAG.GOV/OFFICE-SECTIONS/CONSUMER-PROTECTION/CONSUMER-CREDIT-UNIT/COLLECTION-AGENCY-REGULATION/

The only difference is the url that consumers are pointed to.

The requirement remains that if you can’t fit this language on the front page of your letter, that the letter needs to let consumers know they can find that information on the back of the letter.

This may be a surprise to some of you. For reasons beyond my ken, Colorado hosts the full text of its CFDCPA on LexisNexis, and it has not been updated with this new requirement. But the bill linked above is currently in effect, so if you haven’t worked with your letter vendors for Colorado, maybe that should rise closer to the top of your to-do list.

PHOENIX, Ariz. — Remitter USA Inc, ARM industry’s leader in AI powered digital communication solutions that helps lenders and BPOs optimize customer engagement and maximize revenue, announced today that David Nathanson is the newest member of its executive team. David brings over 20 years’ experience successfully building and leading high performing teams in the banking, financial services, BPO, data, and software spaces.

He joins Remitter as Executive Vice President and Head of Sales after spending the past ten years in a variety of senior leadership roles at Experian, focused on sales, sales engineering, business development, and account management across Collections, Software, Analytics, Fraud & Identity, and Consumer Information. Prior to Experian, David built extensive leadership experience in operations at Capital One, Transunion, and iQor.

“Especially as lenders work through the impact of the pandemic and prepare for the next few quarters of increased delinquencies, they are seeking out scalable and flexible consumer centric solutions,” said Founder, Simon Scalzo. “Remitter is dedicated to meeting these challenges by delivering  a proven platform, technical expertise and client support to fuel increased digital collections for lenders and BPOs.” 

“David’s market expertise, industry connections, and ability to build key relationships fit perfectly within the Remitter team. We’ve been busy this year expanding our executive leadership team across multiple countries and David is another fantastic addition to our growing world class team.”

Nathanson joins the recent key arrivals at Remitter of Executive Vice President of Strategic Partnerships Roxanne Bartley and CFO Jennifer Cummings, as the company continues to add strength to its leadership talent. With additional strategic partnerships, and its’ award winning technology Remitter is primed to bring its omnichannel solutions to all lenders seeking to digitize its customer engagement as customer preferences evolve.

David is excited to be joining the Remitter team, “I knew immediately after reviewing the solutions that Remitter has brought to market, and speaking with the executive team that this was an organization and opportunity that I needed to be part of.”

Today, we embark on Day 2 (of 3) of the iA Strategy & Tech conference. During this virtual event, we polled attendees to see how their companies are solving operational issues, especially now that the impact of COVID-19 will likely linger for a bit. The data is anonymous, but it paints a great picture of where your industry peers stand when it comes to ops, strategy, technology, and adjusting to this “new normal.” Check out the poll results as they stand now.

Editor’s Note: The polls are still active and will remain open throughout the conference. It’s not too late to join the conversation.

Where does your organization stand with these questions? Do you feel in-line with your peers or behind them? Want to join in on the conversation and speak directly to your peers about how they’re handling these issues? 

It’s not too late to register for iA Strategy & Tech. Over 500 collections strategy executives have already signed up for practical, data-rich insight on the industry’s most pressing challenges and plenty of digital networking. What’s more, all sessions from iAST will be available on-demand through the rest of 2020. Click here to sign up.

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Editor’s Note: This article was originally published on the Maurice Wutscher blog and is republished here with permission.

Agreeing with similar rulings in the First, Ninth, and Tenth Circuits, the U.S. Court of Appeals for the Seventh Circuit recently held that the Fair Credit Reporting Act does not require consumer reporting agencies to determine the legal validity of disputed debts.

A copy of the opinion in Denan v. TransUnion LLC is available at:  Link to Opinion.

Factual Background

Two borrowers obtained loans from online payday lenders affiliated with Native American tribes. The loans charged interest in excess of 300% and the terms were subject to and governed by tribal law and not the law of the borrowers’ resident states.

After the borrowers stopped making the monthly payments, the lenders reported the delinquent amounts to a credit reporting agency. One of the borrowers contacted the credit reporting agency and disputed the accuracy of his credit reports because the loan was “illegally issued” such that “there was no legal obligation for [him] to repay.” The credit reporting agency investigated the dispute and verified the accuracy of the information provided by the lender. The other borrower never contacted the credit reporting agency.

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The Consumers’ Claims

The borrowers brought a putative class action against the credit reporting agency, alleging it violated two FCRA provisions: 15 U.S.C. § 1681e(b) — which requires consumer reporting agencies “to assure maximum possible accuracy of the information” contained in credit reports — and 15 U.S.C § 1681i(a) — which requires consumer reporting agencies to reinvestigate disputed items.

The plaintiffs’ claims under each provision presumed that the credit reporting agency transmitted “inaccurate” credit reports.  The borrowers did not claim that the credit reports were factually inaccurate and they did not contest the debt amounts or payment history. Instead, the borrowers claimed the credit reports contained “legally inaccurate” information because the loans were void ab initio under New Jersey and Florida usury laws and therefore “legally invalid debts.”

For their § 1681e(b) claim, the borrowers contended the credit reporting agency “knew or recklessly ignored” that loans made by the lenders were unenforceable, because (1) credit reporting agency’s lender screening procedures showed that the lenders lacked licenses to lend outside of Native American tribal reservations, (2) the same screening procedures showed that the lenders had histories of charging loan interest rates in excess of rates permitted in New Jersey and Florida, and (3) the credit reporting agency allegedly ignored government investigations and enforcement actions in several states — though none of them were in New Jersey or Florida — from which the borrowers alleged “[the credit reporting agency] easily could and should have discovered” that the lenders made illegal loans.

For their § 1681i(a) claim, the borrower who disputed the debt contended the credit reporting agency “failed to use reasonable reinvestigation practices for ascertaining the accuracy of information” contained in his credit report after he disputed the debt.

Procedural Background

The credit reporting agency moved for judgment on the pleadings, arguing that §§ 1681e(b) and 1681i(a) impose a duty to transmit factually accurate credit information, not to adjudicate the validity of disputed debts. The trial court granted the credit reporting agency’s motion, concluding that “[u]ntil a formal adjudication invalidates the plaintiffs’ loans … they cannot allege factual inaccuracies in their credit reports.” The borrowers appealed.

The Seventh Circuit’s Decision

The Seventh Circuit first analyzed § 1681e(b), which requires that “[w]henever a consumer reporting agency prepares a consumer report it shall follow reasonable procedures to assure maximum possible accuracy of the information concerning the individual about whom the report relates.” 15 U.S.C. § 1681e(b). The statute requires a plaintiff to show that a consumer reporting agency prepared a report containing “inaccurate” information. See Walton v. BMO Harris Bank N.A., 761 F. App’x 589, 591 (7th Cir. 2019) (holding a consumer reporting agency “cannot be liable as a threshold matter [under § 1681e(b)] if it did not report inaccurate information”).

The borrowers argued that § 1681e(b) requires consumer reporting agencies to verify the factual and legal accuracy of information contained in credit reports, requiring the consumer reporting agencies to look beyond the data furnished and determine the legality of the borrowers’ loans.

The Seventh Circuit noted the FCRA does not require unfailing accuracy from consumer reporting agencies. Instead, it requires a consumer reporting agency to follow “reasonable procedures to assure maximum possible accuracy” when it prepares a credit report. 15 U.S.C. § 1681e(b); see also Henson v. CSC Credit Servs., 29 F.3d 280, 284 (7th Cir. 1994) (“A credit reporting agency is not liable under the FCRA if it followed ‘reasonable procedures to assure maximum possible accuracy,’ but nonetheless reported inaccurate information in the consumer’s credit report.”).

The Court noted that is a different “accuracy” measure than furnishers are required to follow. “Accuracy,” for furnishers means information that “correctly [r]eflects … liability for the account.” 12 C.F.R. § 1022.41(a). Neither the FCRA nor its implementing regulations impose a comparable duty upon consumer reporting agencies, much less a duty to determine the legality of a disputed debt.

The Seventh Circuit held that what the borrowers called “legally inaccurate” and “legally incorrect” information amounted to non‐adjudicated legal defenses to their debts and only a court can fully and finally resolve the legal question of a loan’s validity. See DeAndrade v. Trans Union LLC, 523 F.3d 61, 68 (1st Cir. 2008) (holding the question of whether a consumer is entitled to stop making debt payments “can only be resolved by a court of law” and is “a legal issue that a credit agency such as Trans Union is neither qualified nor obligated to resolve under the FCRA”).

The Seventh Circuit joined the First, Ninth, and Tenth Circuits in holding that a consumer’s defense to a debt “is a question for a court to resolve in a suit against the [creditor,] not a job imposed upon consumer reporting agencies by the FCRA.” Carvalho, 629 F.3d at 892 (quoting DeAndrade, 523 F.3d at 68); accord Wright v. Experian Info. Sols., Inc., 805 F.3d 1232, 1244 (10th Cir. 2015) (citing Carvalho, 629 F.3d at 892) (“The FCRA expects consumers to dispute the validity of a debt with the furnisher of the information or append a note to their credit report to show the claim is disputed.”).

Therefore, because no formal adjudication discharged the borrowers’ debts, the Court held that no reasonable procedures could have uncovered an inaccuracy in the borrowers’ credit reports.

The Seventh Circuit concluded the borrowers’ § 1681i claim ran into the same problems.

The Court held that, when a consumer disputes the “accuracy of any item of information” contained in a credit report, § 1681i requires consumer reporting agencies to “conduct a reasonable reinvestigation to determine whether the disputed information is inaccurate.” 15 U.S.C. § 1681i(a)(1)(A). Like § 1681e(b), § 1681i requires the “accuracy” of information but does not differentiate between factual and legal accuracy. Yet “one of the most basic rules of statutory interpretation” is that “identical words used in different parts of the same act are intended to have the same meaning.” Ortiz‐Santiago v. Barr, 924 F.3d 956, 962 (7th Cir. 2019) (quoting Sorenson v. Sec’y of Treasury, 475 U.S. 851, 860 (1986)).

Accordingly, as with the borrowers’ § 1681e(b) claim, the Seventh Circuit interpreted inaccurate information under § 1681i to mean factually inaccurate information, as consumer reporting agencies are neither qualified nor obligated to resolve legal issues.

As a result, the trial court’s entry of judgment on the pleadings was affirmed.

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Today, the Consumer Financial Protection Bureau (CFPB) announced that it will host a symposium on July 29, 2020, at 9:30 AM Eastern on the cost-benefit analysis of consumer financial protection regulations. The event, which will be available via webcast (register here), will include remarks from Director Kathleen Kraninger followed by two panel discussions.

The first panel is titled, “Cost Benefit Analysis in Consumer Financial Protection Regulation: Its Use and Agency Incentives.” Panelists include:

• CFPB Moderator: Susan Singer, Deputy Assistant Director, Office of Research 
• Jerry Ellig, Research Professor, George Washington University Regulatory Studies Center
• Stephen W. Hall, Legal Director & Securities Specialist, Better Markets
• Brian Hughes, Executive Vice President and Chief Risk Officer, Discover Financial Services
• Howell Jackson, Professor of Law, Harvard Law School
• Amit Narang, Regulatory Policy Advocate, Public Citizen

The second panel is titled, “Methodological and Subject Matter Considerations.” Panelists include:

• CFPB Moderator: Paul Rothstein, Section Chief, Financial Institutions and Regulatory Policy, Office of Research
• John Coates, Professor of Law and Economics, Harvard Law School
• Mark Cohen, Professor of Law, Vanderbilt Law School
• Alex Lee, Professor of Law, Northwestern Pritzker School of Law
• Christopher J. Mayer, Professor of Real Estate, Columbia Business School

According to the CFPB’s announcement:

The symposium is intended to seek perspectives [on] the use of cost-benefit analysis in consumer financial protection regulations.  The Bureau is exploring developments in the cost-benefit analysis arena and will consider lessons that may be useful as it nears the start of its second decade of work.

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