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The Consumer Financial Protection Bureau (“CFPB”) announced a proposed rule on Feb. 16, 2012 to include debt collectors and credit reporting agencies under its nonbank supervision program. These consumer financial market participants are not currently subject to federal supervision.
The proposed rule includes law firms and covers consumer debt collectors earning more than $10 million from the activity. Based on available data, the CFPB estimates that the proposed rule would cover approximately 175 debt collection firms ' or 4% of debt collection firms ' and that these firms account for 63% of annual receipts from the debt collection market.
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
The parameters set forth in the DOJ's memorandum have implications not only for the government's evaluation of compliance programs in the context of criminal charging decisions, but also for how defense counsel structure their conference-room advocacy seeking declinations or lesser sanctions in both criminal and civil investigations.
This article discusses the practical and policy reasons for the use of DPAs and NPAs in white-collar criminal investigations, and considers the NDAA's new reporting provision and its relationship with other efforts to enhance transparency in DOJ decision-making.
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.