Troutman Pepper Consumer Financial Services COVID-19 Weekly Bulletin – December 2021 # 3 | Man’s pepper with trout


Like most industries today, consumer finance service companies are significantly affected by the novel coronavirus (COVID-19). Troutman Pepper has developed a COVID-19 Resource Center to guide clients through this unprecedented global health challenge. We regularly update this site with COVID-19 news and developments, recommendations from leading healthcare organizations, and tools businesses can use for free.

To help you stay on top of relevant activities, below is a breakdown of some of the biggest COVID-19-related events at the federal and state levels that have impacted the fundraising services industry. consumption last week:

Federal activities

State activities

Privacy and cybersecurity activities

Federal activities:

  • On December 16, the Consumer Financial Protection Bureau (CFPB) issued a series of orders to five companies offering “buy now, pay later” (BNPL) credits. The CFPB is concerned about debt accumulation, regulatory arbitrage and data collection in a consumer credit market that is already evolving rapidly with technology. index. For more information, click on here.
  • On December 16, the Federal Reserve Board and the Federal Deposit Insurance Corporation announced the updated 2022 asset size thresholds used to define “small banks” and “small intermediary banks” under their Community Reinvestment regulations. Act. For more information, click on here.
  • On December 16, the National Credit Union Administration – the federal regulator that oversees credit unions – announced that credit unions can partner with third-party digital asset service providers to give members access to crypto -currencies and other digital assets. Under the new guidelines, credit unions could partner with a third party to allow members to “buy, sell and hold various uninsured digital assets with the third party provider outside of the [federally insured credit union]. “For more information, click on here.
  • On December 16, U.S. Representatives Virginia Foxx and Julia Letlow, both members of the Education and Labor Committee, called for a review of the U.S. Department of Education’s decision to terminate its federal student loan contracts. with private collection agencies. For more information, click on here.
  • On December 13, the CFPB released a Compliance Aid for Electronic Funds Transfers. It includes a series of answers to frequently asked questions. For more information, click on here.
  • On December 8, US Senator Ron Wyden called on the CFPB to prevent credit bureaus from selling Americans’ personal and private data unrelated to their credit or finances through data brokers. For more information, click on here.

State activities:

  • On December 15, the New York Department of Financial Services issued a Notice of regulatory proposal (NPRM) for third party debt collectors and debt buyers. Public comments are now available and are due by February 13. The proposed amendment includes the requirement for validation information either in the initial communication or within five days of the initial communication with a consumer, as well as limits on call attempts and conversations, and guidelines for communicate with consumers by SMS, e-mail and social networks. For more information, click on here.
  • On December 8, the Washington state attorney general pre-tabled a bill that would exempt anyone earning up to 300% of the federal poverty level from any medical bills and offer cuts of up to 400% . of the federal poverty line. Currently, for a one-person household, the federal poverty line is $ 12,880. For a household of four, the limit is $ 26,500. For more information, click on here.

Privacy and cybersecurity activities:

  • On December 16, the Federal Trade Commission (FTC) issued an advance notice of proposed regulations to tackle government and business identity theft fraud, which worsened during the pandemic. Scammers masquerade as government or corporations, resulting in losses of $ 2 billion between October 2020 and September 2021. Since the start of the pandemic, COVID-specific spam reports have included 12,491 complaints of government identity theft and 8,794 corporate identity theft complaints. For more information, click on here.
  • A recent report from the European Commission’s Joint Research Council (JRC) warns of the psychological toll of remote work monitoring on employees. Author Kirstie Bell says surveillance technologies, such as email monitoring, biometrics and webcam recording, create “a very strong sense of invasion of privacy” among workers, which can undermine confidence. To read the full report, click here.
  • On December 16, the White House issued a statement urging businesses to take action against malicious cyber activity, especially in the run-up to the holidays. As individuals continue to work remotely due to the pandemic, the White House has recommended several actions businesses can take, including updating patches, using multi-factor authentication, training employees to make them aware of common cyber attacks and data backup. For the full press release, click here.
  • On December 14, the U.S. Equal Employment Opportunity Commission (EEOC) updated its COVID-19 technical assistance to clarify the circumstances under which COVID-19 may be considered a disability under the Americans with Disabilities Act (ADA) and the Rehabilitation Act. The updates also provide examples of how someone diagnosed with COVID-19 or post-COVID could be considered to have a disability. For example, an employer “risks violating the ADA if it relies on myths, fears or stereotypes about an illness and prevents an employee from returning to work after the employee is no longer. contagious ”. To view technical support, click here.


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