Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32For more information, please visit or 13 RDS TELEPHONE CONSUMER PROTECTION ACT CONSUMER FINANCIAL & PROTECTION BUREAU STUDENT LENDING DEBT COLLECTION The CFPB simultaneously issued a 152-page student loan servicing report analyzing public input and recom- mending servicing reforms, including setting consistent standards across market participants, developing new disclosure requirements, and requiring periodic public reporting. National Bank Ordered to Refund $16 Million and Pay $2.5 Million Penalty. On July 22, the CFPB issued a consent order against a national bank, requiring the bank to refund $16 million to borrowers and pay a $2.5 million civil penalty, settling allegations regarding the third-largest loan originator’s student debt servicing practices. For-Profit Colleges Ordered to Provide $480 Million in Debt Relief. On February 2, the CFPB announced that it had reached a $480 million settlement with ECMC Group and Zenith Education Group, private college consortiums that purchased the now-defunct for-profit Corinthian College, which the CFPB alleged had mis- represented job-placement statistics and the extent of career services offered, and pressured students to take out private, high-interest loans. On September 10, 2015, the Kentucky Attorney General’s Office reached a $12.4 million settlement, resolving similar allegations against Daymar College, another private, for-profit institution. Looking Ahead to 2016 The CFPB is likely to continue focusing on the servic- ing practices of student lenders. Although the CFPB is already investigating some prominent servicers, its most recent Supervisory Highlights identifies a broader array of servicing practices that the CFPB may target in the future, including allocating partial payments to maximize late fees, failing to post-date automatic payments made on weekends, and providing inaccurate information to credit reporting agencies. Additionally, the CFPB has announced its intention to issue student loan servicing rules, the principles for which we expect the CFPB to draw from the mortgage servicing and CARD Act rules. We also expect 2016 will see the reauthorization of the Higher Education Act by Congress, which has the potential to reshape the student lending regulatory environment. We expect the trend of enforcement against for-profit colleges and lenders of students attending for-profit col- leges to continue and that scrutiny of the relationships between the two will heighten. And because general consumer protection statutes have been the favorite tool of federal and state enforcement agencies, a large factor in the number of future student lending enforcement actions will be how expansive an interpretation these enforcement agencies take regarding what is unfair, de- ceptive, and abusive in connection with student loans. Loan Servicing (24%) Debt Relief (29%) For-Profit Colleges (29%) Financial Aid (18%) 24% 29% 29% 18% 2015 AUTO LENDING ENFORCEMENT ACTIONS 2015 STUDENT LENDING ENFORCEMENT ACTIONS BY PRODUCT OR SERVICE MORTGAGE SERVICING 0 5 10 15 20 State Law CFPA Other FCA RESPA ECOA FTCA FHA TILA FIRREA FCRA FDCPA 2015 Enforcement Actions by Statute 0 1 2 3 4 5 6 7 8 DOJ State AGs FTC CFPB What to Watch CFPB supervisory, enforcement, and rule-writing focus on servicing practices | Enforcement against for-profit colleges to continue | Reauthorization of the Higher Education Act