Suzanne Garwood

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Deferred and waived interest programs, convenience checks, promotional rates, and grace periods are popular credit card features with consumer, creditors, and retailers – as well as the Consumer Financial Protection Bureau (CFPB). Last year the CFPB signaled to the industry that it had concerns about use of these loan features and doubts regarding consumer understanding of the proper use of credit containing these features. Earlier this week the CFPB issued Bulletin 2014-02, which provides…
On August 12, the Consumer Financial Protection Bureau (CFPB or Bureau) entered into a consent order with an online mortgage company, its affiliated appraisal company, and its chief executive officer; they agreed to pay $20.8 million to settle allegations of deceptive advertising and illegal lending practices. This particular action, In the Matter of Amerisave Mortgage Corporation et al., reflects the CFPB’s continued focus on mortgage lending and online advertising practices. As such, this enforcement action…
On January 9, 2014, the Federal Trade Commission (“FTC”) announced settlements with nine automobile dealers relating to the advertising of auto sales and leases, one of the largest actions taken by the FTC against automobile dealers: http://www.ftc.gov/news-events/press-releases/2014/01/ftc-announces-sweep-against-10-auto-dealers. The settlements included one or more of the following issues related to the advertising of auto financing or leases.  All consumer products or services companies that offer consumer financing for their products, either directly or through resellers,…
Developing and maintaining a social media presence is seen as a necessary part of business and advertising.  A presence on social media involves not only advertising and running promotions through networking sites, but also becoming an active part of an ongoing dialogue with the ability to respond to customer feedback.  However, communicating in the social media sphere involves a good deal of legal and regulatory uncertainty, which makes some financial institutions hesitant to engage in…