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 3218 key 2015 Trends Federal and state agencies focused on payday lenders who allegedly charged usurious or illegal interest rates, or misrepresented those rates to consumers. While states such as California, Missouri, and North Carolina led the charge at the state level, the CFPB also started to police similar activity where conduct spanned multiple states. Lead-generation firms, which market payday loans to consumers and sell that information to payday lenders, have also been targeted by enforcement agencies, in particular by states where payday lending is illegal but lead-generation companies nonetheless market payday loans to state consumers. The CFPB has also shown that it is willing to take enforcement actions against lead generators despite the companies objecting that they are neither a “service provider” nor “covered person” within the meaning of the Dodd-Frank Act because they do not offer or provide a “financial product or service.” Payday lenders were also targeted by both enforcement agencies and private litigants for engaging in allegedly unlawful or unfair debt collection activities. The chal- lenged practices include electronically withdrawing funds from consumers’ bank accounts, disclosing con- sumers’ debts to third parties, failing to disclose credit payday\small dollar lending In 2015, Goodwin reported on the CFPB’s proposed regulations of payday lending, and the different industry players that have sought to influence the coming regulations. In addition, Goodwin tracked major private actions involving payday lenders, including class actions and lawsuits brought by the government. Goodwin also monitored enforcement actions, private litigation, and regulatory developments related to the payday lending industry. Federal and state agencies initiated numerous investigations, lawsuits, and settlements regarding illegal or usurious interest rates, debt collection, and lead generation companies’ marketing of payday loans to consumers. In one of these actions, the FTC secured its largest recovery ever in a payday lending enforcement action.