See you in Minneapolis! AACANet will be attending the 2019 Spring Conference in Minneapolis, MN.
AACANet has been using the Audit Information Management system developed by ARMGuard Solutions to manage its vendor audits. This program allows AACANet to deploy audit questions, receive responses with supporting documentation and audit the information to assure compliance. While not a replacement for on site visits, AIM helps AACANet oversee its service providers and assure compliance with its standards and the standards of its clients.
The Consumer Financial Protection Bureau (CFPB) indicates that it will issue a Notice of Proposed Rulemaking on debt collections, yet this spring. This time they just may mean it! The CFPB is conducting a survey of major credit card issuers regarding collections practices as part of its Credit Card Market Report for 2019. Rules will likely include direction of communications with consumers and disclosure requirements. CFPB has been working on tests of potential disclosures as part of its research into rules.
Yesterday, Illinois House Bill 88 (formerly HB 281) was approved unanimously by the Illinois House. Blitt & Gaines, through its political action committee, CBCI and its lobbyist, has been working to negotiate a bill that avoids the devastating impact of that the original bill would have had on post-judgment remedies. They are happy to report success. Attached please find what Blitt & Gaines believe will be the final version of the bill. While it still must pass the Illinois Senate, as the House Speaker has endorsed it and made it “his” Bill, we expect few, if any, changes. To summarize HB 88: * Interest on Judgments – Interest on consumer matters (as defined in the statute) shall draw 5% interest rather than 9%. The original version reduced interest to 2%. This section goes into effect upon passage into law. * Judgment Revival – consumer judgments shall be revived no later than the 10th year after entry. It will receive 7 years from the date of revival, giving a potential
CFPB Announces Policy Change Regarding Bureau Civil Investigative Demands WASHINGTON, D.C. – Today the Consumer Financial Protection Bureau (Bureau) announced changes to policies regarding Civil Investigative Demands (CIDs) to ensure they provide more information about the potentially wrongful conduct under investigation. Consistent with the updated policy, CIDs will provide more information about the potentially applicable provisions of law that may have been violated. CIDs will also typically specify the business activities subject to the Bureau’s authority. In investigations where determining the extent of the Bureau’s authority over the relevant activity is one of the significant purposes of the investigation, staff may specifically include that issue in the CID in the interests of further transparency. The new policy takes into account recent court decisions about notifications of purpose, and is consistent with a 2017 report by the Bureau’s Office of Inspector General that em