MINNETONKA, Minn. — Central Portfolio Control (CPC), a full-service and nationally licensed collection agency located in Minnetonka, MN, is proud to make a donation to Metro Meals on Wheels this holiday season and help provide nourishing meals and human connections to seniors and individuals with disabilities throughout the communities that surround the Twin Cities of Minneapolis and Saint Paul, MN. 

Meals on Wheels is a community-based service that delivers fresh, nutritious meals through caring volunteers who provide a social connection that helps meal recipients to live independently in their own homes. Metro Meals on Wheels is an association of 32 Meals on Wheels programs within the Twin Cities metro area that partners with organizations to make sure people in the community receive the nourishment and the human connection they need. 

“The CPC team is proud to help Metro Meals on Wheels keep our neighbors safe, healthy, and nourished while meeting the extraordinary challenges this year has brought into the homes of so many in our community,” says Chief Operating Officer Mike Lesher. 

58% of people who receive home-delivered meals report that the volunteer who delivers their daily meal is often the only person they will see each day. Metro Meals on Wheels volunteers not only deliver nutritious meals and friendly visits, but also safety checks. These daily visits are often a lifeline for this very vulnerable population because they help to battle isolation, identify safety hazards, and provide holistic care that enables the elderly and individuals with disabilities to live nourished lives with independence and dignity. 

“This year, there is an increased demand from those who are struggling and we understand the comfort that predictable meals and daily home visits can bring to people who would otherwise remain isolated and hungry,” continues Mr. Lesher. “We feel a tremendous responsibility to help meet the demands of our community by providing the essential support and services needed by those who are struggling during these uncertain times.”

Community involvement is an important part of Central Portfolio Control’s workplace culture. This donation is part of the company’s commitment to helping neighbors in need and supporting charitable organizations in the community. To learn more about how CPC is actively involved in creating positive change, please visit their News page. 

To support Meals on Wheels in your community, please visit the Meals on Wheels America website. To help our neighbors in the Twin Cities area, you can also visit the Metro Meals on Wheels website.

About Meals on Wheels America

Meals on Wheels America is the leading organization that supports more than 5,000 community-based programs across the country that are dedicated to addressing senior isolation and hunger. Meals on Wheels delivers more than 221 million meals to over 2.4 individuals each year. Serving nearly every community in America, their mission is to empower local community programs to improve the health and quality of life of the seniors they serve so that no one is left hungry or isolated. Metro Meals on Wheels is a local program that serves the Twin Cities (Minn.) metro area. 

About Central Portfolio Control

Headquartered in Minnetonka, Minn., Central Portfolio Control, or CPC, is a full-service and nationally licensed collection agency focused on the recovery of distressed accounts receivable. CPC manages accounts on behalf of our creditor clients while maintaining the highest ethical and legal standards regarding their collection activity. Since being founded in 1998, the CPC team has continued to grow the company by providing top-quality services to our clients and creating jobs within the local community.

CINCINNATI, Ohio — Unifund CCR Partners and Unifund CCR, LLC announces our partnership with Cancer Family Care and our participation in a virtual gift-giving opportunity that helped provide families with an extraordinary holiday season. 

As part of our ongoing commitment to being a powerful force for change and connecting the citizens of our communities with a more promising tomorrow, Unifund teamed up with Cancer Family Care to deliver joy to families who are coping with cancer. Cancer Family Care, a United Way partner agency, is a nonprofit organization that serves children and adults in the Cincinnati/Northern Kentucky region and provides programs and services to support people coping with cancer. Their mission is to strengthen the well-being and alleviate the suffering of children, adults, or families who are dealing with a cancer diagnosis. Through Adopt-A-Family, the Unifund team is helping to bring hope and support to these families this holiday season. 

“The Unifund team cares about making our community a better place to live and we are actively doing so by reaching out and lifting up those in need,” says Jeff Shaffer, Chief Operating Officer. “Many families are struggling to just get by and afford the bare necessities, much less Christmas gifts. And for families struggling with cancer, this time of year can be especially challenging with the desire to take part in holiday activities while battling the stress and fatigue of treatment. We want to make sure the families we adopted have a very special holiday.” 

Supporting Our Community Through Difficult Times

This year, communities are facing enormous challenges and increased needs. The pandemic has disrupted and impacted our lives in so many ways, and for those already struggling or facing personal hardships, this year has brought added stress. Our neighbors are coping with the loss of income, food insecurity, financial hardship, and for some, the anxiety and worry of a cancer diagnosis and associated medical costs. 

Not only has the pandemic magnified the adversity that people are facing, but it’s also created a critical shortage of volunteers on whom charitable organizations rely. Especially as the conditions surrounding COVID-19 worsen across the nation, volunteers are deterred from responding to the continuously increasing demands for help. Many charities are pivoting their response and turning to virtual fundraisers to keep donors actively engaged and involved with outreach efforts. Cancer Family Care’s Adopt-A-Family is embracing this new strategy. Instead of gathering physical gifts and items, the organization created online wish lists through Amazon, allowing families to build their wish lists for donors, like Unifund, to fulfill.  

Bringing Hope to Local Families

By providing Christmas gifts that include basic necessities and special wish list items, the Unifund team hopes to touch the lives of families in our community and provide gifts that they might not otherwise be able to purchase or afford. The families that we are supporting this year have a tremendous need for support. 

“Our team is committed to making a difference whenever there is a chance to do so by giving back to our community in meaningful ways. Through Adopt-A-Family, we hope to alleviate the emotional and financial strain that the holidays can bring while bringing them some holiday cheer,” says Jonathan Wall, Vice President of Growth & Partnerships. “By providing gifts to families whose lives are being impacted by cancer, we can make a tangible difference this holiday; even the smallest of gifts can make a big difference. Our goal is to give them joy and hope by warming their hearts.” 

Unifund is active within the communities in which our employees work and live. Each year, we partner with a select few non-profit organizations with the intent that our charitable contribution will make a measurable impact on their mission. To learn more about how we are helping to create positive change, please visit the Unifund website. To learn more about how you can help support families who are coping with cancer, please visit the Cancer Family Care website. 

About Cancer Family Care

Founded in 1971, Cancer Family Care is a partner agency of the United Way and provides therapeutic counseling, education, and support to help children and adults cope with the effects of a cancer diagnosis in the family. Their services also include free wigs, therapeutic massage, and Healing Touch sessions for cancer patients (with optional reduced rates for caregivers). With six area offices, they ensure the continuity of care with social workers and counselors who make house calls when necessary. Headquartered in Cincinnati, OH, Cancer Family Care is a nonprofit organization that serves the greater Cincinnati/Northern Kentucky areas. 

About Unifund CCR Partners and Unifund CCR, LLC

Founded in 1986, Unifund CCR Partners and Unifund CCR, LLC has been a leading manager and purchaser of distressed consumer receivables. Unifund specializes in managing, servicing, purchasing, and liquidating non-performing judgments and defaulted consumer portfolios from major banks, creditors, originators, financial institutions, and owners of distressed receivables. We believe that our success is interdependent with the well-being of the communities in which our employees live and work and actively partner with multiple charitable organizations each year. Unifund is headquartered in Cincinnati, Ohio.

The Second Circuit was relatively quiet when it came to the Fair Debt Collection Practices Act (FDCPA) and the Telephone Consumer Protection Act (TCPA) in 2020, but when it did issue opinions, several were quite impactful in our industry. Most significant was its decision to side with the Ninth Circuit and its broad interpretation of an automatic telephone dialing system which likely helped set the stage for the Supreme Court to resolve the split in 2021.  The following is a chronological report of the Second Circuit’s opinions in FDCPA and TCPA cases.

Editor’s Note: Want to view these opinions and track other court decision trends that impact the industry? You can do so through a free trial of the iA Case Law Tracker.

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Isaac v. NRA Grp., LLC, 798 Fed. Appx. 693 (2d Cir. 2020)

The Second Circuit affirmed the judgment of the district court that found that collection letters were not required to include the disclosures required by 15 U.S.C. 1692g(a) because they were not the initial communications sent to the debtors by the debt collector.

Bryan v. Credit Control, LLC, 954 F.3d 576 (2d Cir. 2020)

The Second Circuit reversed the dismissal of an FDCPA complaint based upon the alleged failure to identify the creditor to whom the debt is owed as required by 15 U.S.C. 1692g(a)(2).

The letter in issue identified the creditor as Kohl’s, the department store who has private label credit cards that are issued in partnership with Capital One Bank. Even though Kohl’s serviced the accounts and issued all billing statements in their name, the cardmember agreement provided that Capital One was the “creditor and issuer” of the account.

Based upon the language of the cardmember agreement, the Second Circuit held that Capital One was actually the creditor to whom the debt was owed and that the letter should have identified it as such.

Duran v. La Boom Disco, Inc., 955 F.3d 279 (2d Cir. 2020)

In a text messaging case, the Second Circuit threw its hat into the ring to define automatic telephone dialing system (ATDS) under the TCPA. Since the opinion opened by defining the TCPA as having been enacted to “cure America of that ‘scourge of modern civilization’: telemarketing,” one could see where this opinion was headed and the Second Circuit joined the Ninth Circuit in holding that an ATDS need only have the capacity to store or produce telephone numbers to be called, using a random or sequential number generator.

Thus, in the Second Circuit, a predictive dialer is an ATDS. On the human intervention prong, the court took a narrow view and reasoned that click to send was not sufficient human intervention because the system still dials the numbers.

Chaperon v. Sontag & Hyman, PC, 819 Fed. Appx. 61 (2d Cir. 2020)

The Second Circuit affirmed the dismissal of a complaint based on a claim that an initial letter did not quote the language of 15 U.S.C. 1692g(a) verbatim. Specifically, the plaintiff challenged the failure to quote that portion of 1692g(a)(3) and (4) which permits a debtor to dispute “any portion” of a debt when the collection letter did not include the “any portion” language.

Citing to its own prior precedent as well as an opinion from the Sixth Circuit on this very issue, the Second Circuit held that there is no requirement that letters quote the statute verbatim so long as the notices are given effectively.

Wagner v. Chiari & Ilecki, LLP, 973 F.3d 154 (2d Cir. 2020)

In a wrong debtor case, the Second Circuit reversed a district court’s granting of summary judgment based on a bona fide error defense finding that a reasonable jury could find that the defendant did not maintain proper procedures to avoid the specific error that occurred in this case.

Mizrachi v. Wilson, 2020 U.S. App. LEXIS 35189 (2d Cir. Nov. 5, 2020)

The Second Circuit reversed the dismissal of a complaint based on a letter that allegedly overshadowed the validation notice of 1692(g)(a). Specifically, the letter which advised that the matter had been referred to the law firm to file suit stated, in all capital letters “THERE MAY BE NO FURTHER NOTICE OR DEMAND IN WRITING FROM [WILSON] PRIOR TO THE FILING OF SUIT.”

The Second Circuit held that even though there was no date restriction on the filing of the suit or the debtor’s ability to dispute the debt, the threat of the suit and its consequences could mislead a debtor into believing that immediate payment was the only way to avoid these consequences thus overshadowing the debtor’s validation rights.

Helpful Opinions e.g. “Check the Fine Print”

The Second Circuit definitely did not make any new friends among debt collectors with its bombshell TCPA opinion in Duran but offered a few helpful opinions under the FDCPA with Isaac, holding that the requirements of 1692g only apply to the initial communication and not subsequent letters and Chaperon, which held that one need not quote 1692g verbatim in collection letters so long as the validation notice is still conveyed effectively.

But Bryan will make collectors check the fine print with their clients to make sure they know the correct legal entity for whom they are collecting. Mizrachi is another in a long line of threatened suit overshadowing cases that should cause concern for collection attorneys. Finally Wagner may make summary judgment on a bona fide error defense very difficult and make all such cases jury questions.

The time has finally come. After the governor’s approval of California’s Debt Collection Licensing Act and the California Consumer Financial Protection Law back in September, California’s new mini-CFPB—now called the Department of Financial Protection and Innovation (DFPI)—is officially in business. And, from the sound of it, DFPI intends to hit the ground running.

In a press release issued yesterday, DFPI announced that it will begin its work “immediately.” What’s on the docket? Several key points immerged. Read on to see the five main items DFPI has on its radar according to its announcement.

Consumer complaints

“[T]he DFPI will review and investigate consumer complaints against previously unregulated financial products and services, including debt collectors, credit repair and consumer credit reporting agencies, debt relief companies, rent to own contractors, private school financing, and more.”

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Market monitoring and research

“The DFPI is also in the process of standing up a new Division of Consumer Financial Protection that will feature a market monitoring and research arm to keep up with emerging financial products. Consumer outreach to target vulnerable populations, such as students, new Californians, military servicemembers and senior citizens will be expanded. An ombudsman will help independently investigate complaints against the Department and work to resolve process issues.”

Innovation

“The Department is also preparing to open a new Office of Financial Technology Innovation that will engage with new industries and consumer advocates to encourage consumer friendly innovation and job creation in California. This expansion will allow department representatives to work proactively with entrepreneurs and create a regulatory framework for responsible, emerging financial products.”

Consumer Education

“This spring, the DFPI will launch a statewide campaign to educate California consumers on how the department can support and protect consumers. Offering translation services in dozens of languages, the DFPI hotline will help all Californians. DFPI representatives never ask questions about a callers’ immigration status.”

Department growth

“To focus on these new activities and expanded charge, the DFPI will hire 90 additional employees over the next three years. The staffing increases will be financed from department reserves for the first three years. After that, the department projects increased annual costs of $19.3 million. The additional employees represent a 13 percent staffing increase.”

insideARM Perspective

Murmurs of a mini-CFPB in California have been going around for a while, starting in April 2019 when California Assemblywoman Monique Limón (D-Santa Barbara) initially explored the creation of the state agency with the federal Consumer Financial Protection Bureau’s former director Richard Cordray at her side. Corday also advised California’s governor on a potential state consumer protection agency about a year ago. 

With Cordray’s influence in California and the anticipated change in directorship once President-elect Biden — who was Vice President went the CFPB was formed and Cordray was appointed as its first director — takes office later this month, we are either entering a new era of consumer finance regulation or a season of déjà vu from the early 2010’s. Either way, it’s going to be a busy year for the industry.

ITASCA, Ill. — Brown & Joseph / Altus and Paragon Asset Recovery Services Inc. (Paragon), leading providers of commercial accounts receivable services to the insurance industry, are proud to announce that they have merged their companies to further broaden the breadth of services they bring to their combined client portfolio.     

Mike Baldwin, CEO at Brown & Joseph / Altus, comments, “We are so proud to join forces with the highly respected team at Paragon. We have been great business partners for many years and now we are all a part of the same family. Paragon’s deep industry expertise, world class client base, highly talented team members and their commitment to an internal culture based on interpersonal respect and associate satisfaction fit incredibly well with the Brown & Joseph / Altus strengths and values.”

Joe Warnagiris, CEO at Paragon, adds, “We are excited to enter into this partnership with Brown & Joseph / Altus. Paragon’s expertise in identifying missed claim assets, subrogation, and liability deductibles along with Brown & Joseph’s proficiency in recovering insurance receivables is a very powerful combination. The merger will allow our united organization to offer an even more comprehensive set of solutions to our customers and to the industry.” 

There are no plans to change any aspects of any client’s relationships at either Brown & Joseph / Altus or at Paragon. All direct and indirect aspects of supporting clients will remain the same. Although they are now one company,  both the B&J/Altus and Paragon brands will continue on in the marketplace.

The existing relationship between Brown & Joseph / Altus and Paragon is significant as they have been highly valued business partners since 2014. Both companies are also steadfast supporters of Insurance Collection Executives (ICE), proving their deep-rooted investment in the insurance industry. 

Please call either Dave Robbins at (847) 621-6137 or Joe Warnagiris at (412) 375-6413 if you have any questions or if you would like to learn more about the combined capabilities of this great new company.

Just before the new year, the Federal Communications Commission (FCC) issued a critical report and order implementing section 8 of the TRACED Act—specifically, the FCC has reviewed all of its previous content-specific exemptions under the Telephone Consumer Protection Act (TCPA) to provide the additional findings Congress required. Most importantly the FCC limited the call volumes permitted under four commonly-used exemptions, including a limit on call made to residential lines using an artificial or pre-recorded voice. Read on for more info on each of the four items.

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1. Non-commercial calls to a residence 

Citing the numerical limitations on the number of calls that can be made to a wireless number under the exemptions authorized by section 227(b)(2)(C), “we therefore amend our rules to limit the number of calls that can be made to a particular residential line pursuant to this exemption to three artificial or prerecorded voice calls within any consecutive 30-day period. We thus require callers to allow recipients of artificial and prerecorded voice message calls made under this exemption to opt out of such calls using either of the mechanisms described in our rules” (47 C.F.R. 64.1200(b)(2) and (b)(3).

2. Commercial calls to a residence that do not include an advertisement or constitute telemarketing

“We therefore limit the number of calls that can be made pursuant to this exemption to three artificial or prerecorded voice calls within any consecutive 30-day period.” “We also require callers to allow recipients of artificial and prerecorded voice message calls made pursuant to the exemption for commercial calls to opt out of such calls using either of the mechanisms described in our rules.”

3. Tax-exempt nonprofit organization calls to a residence

“We therefore limit the number of calls that can be made pursuant to this exemption to three artificial or prerecorded voice calls within any consecutive 30-day period. . .We also require callers to allow recipients of artificial and prerecorded voice message calls made pursuant to the exemption for tax-exempt nonprofit organizations to opt out of such calls using either of the mechanisms described in our rules.”

4. HIPAA-related calls to a residence

“We therefore amend our rules to limit the number of calls that can be made pursuant to this exemption to one artificial or prerecorded voice call per day up to a maximum of three artificial or prerecorded voice calls per week. . .We require callers to allow recipients of artificial and prerecorded voice message calls made pursuant to the HIPAA exemption to opt out of such calls using either of the opt-out mechanisms described in our rules.”

Implementation and Effective Date: Six Month Period

The FCC notes that it recognizes that the implementations of the call volume limits might present a burden to those placing calls and, therefore, established a six-month implementation period starting on the date when the ruling is published in the Federal Register

You can find the full report and order here: FCC EXEMPTIONS REPORT AND ORDER

Part 2 is here and, at long last, we now have the complete final debt collection rule — Regulation F — from the Consumer Financial Protection Bureau (CFPB or Bureau). This part of the rule relates to validation notices, time-barred debt, and passive debt collection. How did the final rule come down on these topics? Continue reading to find out.

Validation Notice — Basically What Was Proposed

If you were hoping for some wild modification of the model validation notice presented in the proposed rule, you’ll be disappointed. The Bureau’s final rule on the validation notice is largely the same as the proposal — tear-off and all. If a debt collector wants to take advantage of the safe harbor, they have to largely have their collection notice mirror the model notice. If a state requires its disclosures to be on the front page of a collection letter, then that is allowed. Otherwise, state disclosures are allowed on the reverse side of the letter.

Time-Barred Debts — Large Departure from Proposal

This section is where the Bureau took the biggest departure from the proposal. Specifically, the Bureau decided not to mandate a time-barred debt disclosure, which means that it’s business as usual in this respect. The Bureau, however, did go forward with its prohibition of suing on a time-barred debt.

Debt Parking/Delayed Credit Reporting

The Bureau finalized its proposal against debt parking, or the process of credit reporting the debt prior to communicating with the consumer. The final rule requires that debt collectors send a communication about the debt to the consumer. If that communication is in writing, the debt collector must wait a reasonable time — to ensure there are no deliverability issues — before they are allowed to credit report the account. The Bureau defined “reasonable time” as 14 days when it comes to traditional mail. Unfortunately, it seems that the Bureau also applied a 14-day “reasonable time” to electronic communications, which is odd considering that notifications that a system could not deliver an electronic message are almost instantaneous. On the bright side, the Bureau is open to receiving data as the rule gets implemented and potentially revisiting some of these items.

Effective Date — Aligned for Parts 1 and 2

The full final rule will have one effective date: November 30, 2021.

You can download Part 2 here: Debt Collection Practices (Regulation F) Part II

Part 2 is here and, at long last, we now have the complete final debt collection rule — Regulation F — from the Consumer Financial Protection Bureau (CFPB or Bureau). This part of the rule relates to validation notices, time-barred debt, and passive debt collection. How did the final rule come down on these topics? Continue reading to find out.

Validation Notice — Basically What Was Proposed

If you were hoping for some wild modification of the model validation notice presented in the proposed rule, you’ll be disappointed. The Bureau’s final rule on the validation notice is largely the same as the proposal — tear-off and all. If a debt collector wants to take advantage of the safe harbor, they have to largely have their collection notice mirror the model notice. If a state requires its disclosures to be on the front page of a collection letter, then that is allowed. Otherwise, state disclosures are allowed on the reverse side of the letter.

Time-Barred Debts — Large Departure from Proposal

This section is where the Bureau took the biggest departure from the proposal. Specifically, the Bureau decided not to mandate a time-barred debt disclosure, which means that it’s business as usual in this respect. The Bureau, however, did go forward with its prohibition of suing on a time-barred debt.

Debt Parking/Delayed Credit Reporting

The Bureau finalized its proposal against debt parking, or the process of credit reporting the debt prior to communicating with the consumer. The final rule requires that debt collectors send a communication about the debt to the consumer. If that communication is in writing, the debt collector must wait a reasonable time — to ensure there are no deliverability issues — before they are allowed to credit report the account. The Bureau defined “reasonable time” as 14 days when it comes to traditional mail. Unfortunately, it seems that the Bureau also applied a 14-day “reasonable time” to electronic communications, which is odd considering that notifications that a system could not deliver an electronic message are almost instantaneous. On the bright side, the Bureau is open to receiving data as the rule gets implemented and potentially revisiting some of these items.

Effective Date — Aligned for Parts 1 and 2

The full final rule will have one effective date: November 30, 2021.

You can download Part 2 here: Debt Collection Practices (Regulation F) Part II

PITTSBURGH, Pa. — Credit Management Company announced today that following a long and incredibly successful 40-year career, Mary Lou Muti is retiring, effective March 31st, 2021. 

 “Mary Lou has held several integral roles throughout her illustrious career with Credit Management Company. The culture and commitment to exceptional customer service that exist at Credit ‘Management Company can be attributed to Mary Lou’s vision and leadership.  We are grateful to her for her guidance, support, and positive demeanor. She will certainly be missed,” said Joel McKiernan, Executive Vice President of Sales. 

Muti, who started with Credit Management Company in 1981 as an administrative assistant, has been president for 10 years. Prior to her current role, she held the titles of Office Manager, Controller, Vice President of Finance, and finally Executive Vice President, before becoming president in 2010. Under her leadership, the company saw expansion into new geographic regions, long-lasting client partnerships, and multiple financial successes, including a record-setting year in 2020.  

Credit Management Company is proud to announce the promotion of Joel McKiernan to President, effective January 1st, 2021. Joel will be the third president in CMC’s 54-year history. 

Joel began his career at CMC in 2013 and brought with him over 22 years of experience in the healthcare revenue cycle industry. He has played a critical role in managing and directing our sales force and with new market and product development.

Joel has thrived as VP of Sales and has maintained a close rapport with clients over the past 7.5 years. Joel’s ability to nurture current client relationships while fostering and cultivating new ones has helped earn Joel his new position.

About Credit Management Company (CMC)

CMC has been providing full-service accounts receivable and collection management programs across several industry segments since 1966. Headquartered in Pittsburgh, Pennsylvania, CMC’s clients reside in the healthcare, government, education, and consumer industry sectors. CMC’s customized outsourcing processes deliver solutions that will accelerate cash flow, lower operating expenses, reduce customer delinquency, and improve customer care and support. All of CMC’s vast client network has benefited from either CMC’s standard or customized outsourcing programs to improve their bottom line.

CMC is proud of the partnerships they have cultivated over the years. Each business relationship is approached in a collaborative style, and always involves listening and responding to client’s needs.

The end of the year is my favorite — it’s the perfect time to review what’s happened in the courts over the past twelve months. While 2020 might have been a wild ride in many other areas, it’s been a good year for case law favoring the debt collection industry.

Since January 1, 2020, we’ve added a whopping 634 cases into the CLT. Of those cases, a majority came down positive for the debt collection industry! Below is the breakdown of the overall dispositions:

• Positive: 361 (57%)
• Mixed: 84 (13%)
• Negative: 179 (28%)
• Neutral: 10 (2%)

There were many substantive issues that dominated the court dockets this year, including:

• Credit reporting dispute procedures (41 cases: 25 positive, 12 negative, and 4 somewhere in between)
• Letter formatting/overshadowing (27 cases: 17 positive, 3 negative, and 7 somewhere in between)
• Time-barred debt (25 cases: 13 positive, 8 negative, 4 somewhere in between)
• Creditor ID (25 cases: 14 positive, 6 negative, 2 somewhere in between)

There’s one issue that gets a shout-out for starting to cause a scene on the dockets, and that’s payment processing fees—sometimes called “pay to pay” fees. We began to see more court decisions on this issue, and the results are all over the place. Of the 9 court decisions in the CLT, 5 are positive, 3 are negative, and 1 is mixed. 

The entire insideARM team is going to be out on vacation for two weeks starting next week, so we’ll see you all on the flip side in 2021 (except for a brief interlude when Part 2 of the CFPB’s final rule is released).

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