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 3224 consent when he provided his telephone number in connection with the debt. JPMorgan Chase Bank Ordered to Pay $200 Million. On July 8, 2015, the CFPB and attorneys general from 47 states issued a consent order requiring JPMorgan Chase Bank to pay $200 million to settle claims that its debt-sale practices were unfair and that it provided substantial assistance to debt buyers’ deceptive collection practices. The bank allegedly sold accounts that were inaccurate, settled, discharged in bankruptcy, not owed by the consumer, or otherwise uncollectable, and allegedly filed lawsuits and obtained judgments using affidavits and other improper documents. California AG Secures $100 Million Settlement with JPMorgan Chase Bank. On November 2, 2015, the California Attorney General’s Office agreed to a $100 million stipulated judgment with JPMorgan Chase Bank, resolving allegations that JPMorgan engaged in abusive debt collection practices related to defaulted consumer credit card accounts. The alleged practices include robo-signing affidavits in debt collection lawsuits, miscalculating amounts borrowers’ owed, and reporting inaccurate amounts to credit reporting agencies. FTC Brings “Operation Collection Protection” Actions. On November 4, 2015, the FTC announced a new joint enforcement initiative with state attorneys general targeting debt collection companies, with the goal of bringing civil and criminal enforcement actions against debt collection companies engaged in illegal collection tactics. Through this initiative the FTC brought 115 actions last year in conjunction with 70 state and federal agencies. FTC Launches “Messaging for Money” Enforcement Initiative. The FTC secured several injunctions in federal courts against debt collectors as part of its enforcement initiative targeting practices such as the failing to provide statutorily required notices, sending misleading text messages to consumers, or threatening to arrest a consumer or contact family members. Looking Ahead to 2016 The CFPB’s 2015 rulemaking agenda notes that it is conducting research on possible additional regulations of the debt collection industry. Because debt collection is the largest source of consumer complaints received by the CFPB, debt collection is likely to remain in the CFPB’s crosshairs. Future enforcement activity will likely continue to focus on banks and ensuring proper debt collection practices targeted in recent consent orders, including banning debt buyers from reselling accounts, requiring that debts be confirmed before they are sold to third parties, and providing account-level documentation to debt buyers to confirm that the debts are accurate and enforceable before the accounts can be sold. Because student debt continues to balloon, federal enforcement actions related to student debt relief service providers also may become more prominent. What to Watch Additional regulations | Sale of debts to third-parties subject to enhanced scrutiny by regulators | Scrutiny of student loan debt relief providers PAYDAY LENDING TELEPHONE CONSUMER PROTECTION ACT DEBT COLLECTION