insideARM Weekly Recap – Week of June 3rd, 2024

Here at insideARM we aim to do the hard work for you! Scouring the internet for ARM Industry news and narrowing it down to the 3 biggest stories. The first week of June brought us a breakdown of the CFPB’s activity in May, the most recent CFPB action, and some credit card data from the Federal Reserve. So, sit back, relax, and read on for our recap of last week’s news and why you need to know about it!

On Tuesday, we highlighted an analysis of Q1 data from the Federal Reserve on credit card charge-offs and delinquencies. The 2024 numbers from the first quarter still indicate an increase in charge-offs but the curve is flattening out. The delinquency rate data tells a similar story of an increase but one that might indicate a peak in the near future. This is the kind of information that can allow you and your business to plan for what is coming. With an estimated 9-12 months between charge-off and litigation, this data can help collectors know when to expect an increase in volume.

Wednesday, we brought you the CFPB Bites for the month of May. Last month was a busy one for the CFPB. This included a collaboration with the Federal Reserve Board regarding inflation-adjusted dollars, data and reports on everything from overdraft revenue to credit reporting medical debt, a renewed attack on “junk fees” in mortgage servicing, and a number of actions against student loan servicers, a for-profit school, and a fintech company. It is easier to keep up with the big stories but, tracking the smaller actions of the CFPB is essential to working within the ARM industry. This is where you find the clues to where they are focusing enforcement and what issues they may take aim at next. And they are not subtle. If the CFPB says they are taking a look at something, they already have and likely drafted a rule.

We finished the week on Thursday with another CFPB bombshell. In a near 500-page document, the CFPB issued a final rule on the registration of enforcement orders. The rule requires most “covered persons” under the Dodd-Frank act to register with the CFPB any public orders that stem from an action brought by a federal agency. This will include any relevant orders as far back as January 1, 2017. Bottomline: This is a big deal. It creates a new hurdle for compliance, threatens to shame those who have faced government enforcement actions, and could be an indication that aggressive CFPB enforcement is on the horizon.

As always, we thank you for reading the weekly recap to stay on top of this ever-changing industry! For a breakdown of the week of May 27th, click here.

Have a question about how your company should react to the news above? We have a group for that! The weekly peer call hosted by insideARM’s Research Assistant is the perfect place to ask a question and get advice from industry colleagues who are facing the same challenges you are. Not sure if it is for you? Try it on for size with our 1-month free trial. Click here to learn more!