Central District Consumer Bankruptcy Attorney's Association

FYI ... (
BTW I am a member of the CFSC. If you have any issues, concerns or CA legislative ideas, please contact me off of the listserv.
Eric
Law Office of Eric Alan Mitnick
21515 Hawthorne Boulevard, Ste. 1080
Torrance, California 90503
(310) 792-5864; 792-5866 (fax)
MitnickLaw@aol.com
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To: Sections: BLS Consumer Financial Services Cmte. Constituency List
Sent: Wed, Feb 22, 2012 12:42 pm
Subject: Update from the State Bar Business Law Section's CONSUMER FINANCIAL SERVICES COMMITTEE
Business Law Section of the State Bar of California
Consumer Financial Services E-Bulletin
William Webb
Chair
Webb Legal Group
155 Montgomery St, Ste 1200 San Francisco, CA 94104
415-277-7200
FAX 415-277-7210 wwebb@webblegalbroup.com
Jill Kovar
Vice Chair, Programming
Aldrich Bonnefin & Moore, PLC 18500 Von Karman Ave Ste 300 Irvine 92612
949-474-1944
FAX 949-474-0617 jkovar@abmlawfirm.com
Martha King
Vice Chair, Membership
1366 Hermes Avenue
Encinitas, CA 92024
760-942-3580 ccmarthaking@gmail.com
Rita Lin
Vice Chair, Communications Morrison & Foerster LLP
425 Market St
San Francisco, CA 94105-2482
415-268-7466
FAX 415-268-7522
rlin@mofo.com
Victoria Allen
Vice-Chair, Legislation & Publications
Law Office of Thomas H Wolfe 1809 Eastgate Ave
Upland, CA 91784
909-944-1043 vlsa@twolfelaw.com
CFPB Proposes Rule Regarding Supervision of Large Debt Collectors and Consumer Reporting Agencies
Last Thursday, the Consumer Financial Protection Bureau (CFPB consumer reporting agencies in its supervision of nonbank entities.
Dodd-Frank authorizes CFPB to supervise nonbanks that are "larger participants" in the consumer financial produts and services market. The Act gives the CFPB until July 21, 2012 to define "larger participants." Thursday's proposed rule is the first in a series of planned rulemakings to define that term.
The proposed rule treats debt collectors with more than $10 million in annual receipts and consumer reporting agencies with more than $7 million in receipts as "larger participants." The CFPB estimates that this would subject approximately 175 debt collection firms (comprising 63% of annual receipts in that market) and 30 consumer reporting agencies (comprising 94% of the annual receipts in that market) to supervision.
In selecting these two markets for its initial rulemaking, the CFPB emphasized the considerable impact that debt collectors and consumer reporting agencies have on American consumers. The CFPB further noted that it used annual receipts as an indicator of size because it "approximates market participation" in those two markets, but that it might use different criteria to assess size in other markets.
The comment period on the proposed rule will be open for 60 days from the date of publication of the proposed rule in the Federal Register.
For more information about this topic, please contact Rita Lin at Morrison & Foerster LLP in San Francisco.
For more information about the Business Law Standing Committees, please see the standing committees web page.
These periodic e-mails are being sent to you because you expressed interest in receiving updates from the Consumer Financial Services Committee of the State Bar of California's Business Law Section. As a Section member, if you would also like to sign up to receive e-bulletins from other standing committees, simply click HERE and follow the instructions for updating your e-bulletin subscriptions in My State Bar Profile. If you have any difficulty or need assistance, please feel free to contact Susan Orloff Section Coordinator of the Business Law Section. If you are not a member, or know of friends or colleagues who might wish to join the Section to receive e-bulletins such as this, please click HERE to join online.
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