Joshua Dachs

Josh Dachs is an Attorney in the Financial Services Litigation section of Troutman Sanders. Josh focuses on helping clients navigate financial services laws, including consumer protections, business disputes and commercial litigation.

Firm/Organization: Troutman Sanders LLP

Blogs: Consumer Financial Services Law Monitor

Latest Articles

Consumer Financial Services Law Monitor

Massachusetts to Join Other States in Regulating Student Loan Servicers

By Stephen Steinlight, Joseph DeFazio & Joshua Dachs

December 2, 2019

Massachusetts is proposing a bill to regulate student loan servicers and bring the Commonwealth in line with other states, including Connecticut, Colorado, Illinois, Maine, Maryland, Nevada, New Jersey, New York, Rhode Island, and Washington, all of which have passed new legislation to regulate the student loan industry. Similar legislation recently has been introduced, but not yet passed, in Iowa, Minnesota, Missouri, New Mexico, North Carolina, California, and Oregon to regulate the student loan servicing industry.…

Consumer Financial Services Law Monitor

New York Adopts Final Regulations for Student Loan Servicers

By Stephen Steinlight, Joseph DeFazio & Joshua Dachs

December 2, 2019

Effective October 16, the New York State Department of Financial Services adopted final regulations impacting student loan servicers operating in the state. The legislation, titled Article 14-A, passed in April 2019 and imposes new licensing requirements and servicing standards on institutions that service loans for borrowers residing in New York. The new regulations will affect more than two million student loan borrowers in New York. Troutman Sanders previously reported on the proposed regulations in August. The…

Consumer Financial Services Law Monitor

Sock Maker Bombas Settles with New York AG Over Failure to Notify of Credit Card Data Breach

By Stephen Steinlight, Joshua Dachs & Megan Burns

July 23, 2019

Bombas, a manufacturer of socks, settled with the New York Attorney General over failing to give proper notification of a breach of customers’ credit card data in 2014. Bombas initially addressed the breach in 2014 when it determined that hackers had gained access to the information of nearly 40,000 customers, including names, addresses, and credit card numbers, by inserting a malicious code into Bombas’ ecommerce platform, Magento. Of the nearly 40,000 customers impacted, approximately 3,000…

Consumer Financial Services Law Monitor

FINRA Provides New Guidance to Member Firms on Extraordinary Cooperation Credit

By Stephen Steinlight, Joshua Dachs & Megan Burns

July 23, 2019

On July 11, FINRA issued Regulatory Notice (RN) 19-23, providing new details on how member firms and associated persons can receive credit for “extraordinary cooperation” with an investigation. RN 19-23 expands on RN 08-70, issued during 2008, by providing specifics as to what actions an investigated party could undertake to support its efforts in seeking this credit. Other prior rules in place regarding reporting and cooperation requirements gave rise to uncertainty about what qualifies as extraordinary…

Consumer Financial Services Law Monitor

FINRA Proposes Rule to Aid Prevailing Customers and Investors with Unpaid Arbitration Awards Against Broker-Dealers

By Stephen Steinlight, Joshua Dachs & Megan Burns

May 9, 2019

On May 2, the Financial Industry Regulatory Authority announced a new proposal targeting brokerage firms with questionable disciplinary histories. In a Regulatory Notice released on its website, FINRA announced that it is considering a plan to require member firms with a high number of registered representatives with disciplinary histories to pay into a fund that would be overseen and controlled by FINRA. The proposed fund would be held in reserve and the money used, upon FINRA’s…

Consumer Financial Services Law Monitor

District of New Jersey Dismisses TCPA Claim with Rule 11 Sanctions Under Review

By Stephen Steinlight, Joshua Dachs & Megan Burns

May 8, 2019

Nearly half of all calls to U.S. cell phones in 2019 will be spam. This statistic is according to a study referenced by the Federal Communications Commission in a recent report, Report on Robocalls, CG Docket No. 17-59, A Report of the Consumer and Governmental Affairs Bureau, Federal Communications Commission (February 2019). In this environment of pervasive spamming, it seems hard to imagine that anyone would need to fictionalize such a call to justify bringing a…

Consumer Financial Services Law Monitor

It is the New Jersey Consumer Fraud Act, Not the New Jersey Breach of Contract Act

By Stephen Steinlight, Joshua Dachs, Megan Burns & David N. Anthony

May 8, 2019

On March 29, in Marshall v. Verde Energy USA, Inc., Judge John Vazquez of the United States District Court for the District of New Jersey dismissed a plaintiff’s putative class action lawsuit against Verde Energy, finding, in part, that the plaintiff failed to state a claim under the New Jersey Consumer Fraud Act (“CFA”). Marshall v. Verde Energy USA, Inc., No. 18-cv-1344, 2019 WL 1254562 (D.N.J. Mar. 19, 2019). In so holding, Judge Vazquez bolstered existing…

Consumer Financial Services Law Monitor

CFPB Reports on Mortgage Complaint Trends in New York and New Jersey

By Stephen Steinlight, Joshua Dachs & Megan Burns

February 15, 2019

On January 29, the Consumer Financial Protection Bureau released a snapshot report of consumer complaints to provide a high-level overview of the trends in complaints it has received over the past 24 months. The report is split into two sections – a summary of the volume of all consumer complaints received by the CFPB per state and consumer financial product type, and a highlight of mortgage-related complaints. The CFPB’s snapshot reveals it received 7 percent fewer…

Consumer Financial Services Law Monitor

CFPB Announces New Senior Leadership

By Stephen Steinlight, Joshua Dachs & Megan Burns

February 15, 2019

On January 25, Consumer Financial Protection Bureau Director Kathleen L. Kraninger announced senior leadership changes within the Bureau, appointing five new members to the CFPB leadership team. Kraninger, a recent appointee by President Donald Trump, previously served in the White House Office of Management and Budget in the Trump Administration. The following individuals will join her among CFPB leadership: Andrew Duke joins the CFPB as Policy Associate Director for External Affairs. Duke’s background involves twenty…

Joshua Dachs

Massachusetts to Join Other States in Regulating Student Loan Servicers

New York Adopts Final Regulations for Student Loan Servicers

Sock Maker Bombas Settles with New York AG Over Failure to Notify of Credit Card Data Breach

FINRA Provides New Guidance to Member Firms on Extraordinary Cooperation Credit

FINRA Proposes Rule to Aid Prevailing Customers and Investors with Unpaid Arbitration Awards Against Broker-Dealers

District of New Jersey Dismisses TCPA Claim with Rule 11 Sanctions Under Review

It is the New Jersey Consumer Fraud Act, Not the New Jersey Breach of Contract Act

CFPB Reports on Mortgage Complaint Trends in New York and New Jersey

CFPB Announces New Senior Leadership

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