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PB  TIME TO LIVE                                                                             TIME TO LIVE      23
 YOUR DREAMS                                                                                  YOUR DREAMS






        CONSUMERS:


        WHY WHERE YOU SPEND MATTERS!



        Trade Financing Matters welcomes   acts. They’re trying to preserve the
        this guest post from Susan Joseph,   relationship and argue it would be
        a former General Counsel of a   bad business for them to behave
        start-up peer lending financial   badly.
        services/tech disrupter.      Of course, some banks have
          The Consumer Financial    already engaged in some of these
        Protection Bureau (CFPB) was   bad acts, so Consumer groups
        created by the Dodd-Frank Act and   think the CFPB should regulate the
        is a US government agency whose   entire credit life cycle from debt
        mandate is to protect consumers   buyers, collectors, and first party
        of financial services and   creditors to banks collecting both
        products. This means there are   for themselves and others to “even
        strong federal rules that protect   the playing field.” Expect a big
        consumers. It also means there is   fight here.
        federal enforcement if you break   Payday Lending: If this
        those rules, and that enforcement   part of the ecosystem is
        can result in injunctions that   regulated, it will affect
        shut your business or fines and   the banks, nonbanks
        penalties.                  and online lenders
          The CFPB has a broad reach   because the CFPB
        and can specifically make rules   can regulate all those
        effecting banks, payday lenders,   parties. Marketplace
        mortgage servicers, debt collectors   lenders offering this
        and other financial companies and   product should keep
        can regulate virtual currencies.   a close eye on this.
        Since its creation, it has collected   If, for example, the
        millions of dollars in restitution   amount of times
        and penalties and is considered a   a consumer can
        vigilant if not aggressive consumer   draw credit within a
        advocate. If the CFPB determines   certain timeframe
        there is a violation, it can bring   is limited, the
        an enforcement action-the type   platform algorithms
        you hope you never see in the   and pricing
        headlines.                  will have to be
          An article from January 9   adjusted and
        National Mortgage News has   perhaps entire
        some telling predictions about the   business model
        CFPB’s agenda.              will have to
          Debt Collection: Significant   evolve as
        rules will likely be adopted to   well.
        address debt collection. How far
        will they go? The Banks are hoping
        to escape the rules and claim their
        unique relationship as the first
        party with the credit and deposit
        relationship deters them from
        engaging in bad debt collection
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