insideARM Weekly Recap – Week of July 8th, 2024

insideARM is here to help you keep up with the fast-paced ARM industry. This often requires keeping a finger on the pulse of the regulatory bodies, providing advice for more efficient collections, and reporting on state-level legislation. Last week was a perfect example of this as we brought you the most recent focus from the CFPB, guidance for an effective settlement program, and a recent amendment to data breach notification laws in Pennsylvania. Keep reading for the highlights from these stories and why our editorial team thinks they are important!

Our Tuesday news was a breakdown of the CFPB’s Supervisory Highlights for the summer. The Bureau touched on three concerning areas for the ARM industry: student loan servicing, disclosure violations, and harassment. Student loans have been on the CFPB’s radar for some time, and this document takes exception to potential UDAAP violations when it comes to the servicing of those loans. As for debt collectors, the supervisory highlights touched on validation violaitons, misleading consumers about their rights, and harassing consumers with call volume and aggressive language. As with everything the CFPB publishes, it should be read as if it is a glimpse into the future. The things the Bureau expresses concern about often become rules, regulations, and enforcement actions. So, the industry should take note and prepare accordingly.

Wednesday, we highlighted an article about the keys to an effective repayment program strategy. Coming to an agreement with a consumer on a repayment plan can be broken down into two essential elements: the available settlement offers and the conversation with the collector. While it may seem like a good idea to have a wide variety of options for the consumer to choose from, it is more important to provide the right offer. This article provided steps to improve and refine processes, which should be a top priority for any company working with consumers on past due accounts.

We finished the week with an amendment to Pennsylvania’s data breach notification law. Senate Bill 824 was signed into law at the end of June and goes into effect on September 26, 2024. The amendment changes notification requirements, lowers the threshold that triggers a notification from 1,000 affect individuals to more than 500, and requires the entity to provide a credit report and a year of credit monitoring services to affected individuals. It is often said that there are two types of companies: those who have been hacked, and those who will be hacked. While companies should take all reasonable steps to prevent a data breach, it is essential to pay attention to both new laws and changes so your organization can ensure it has the best possible plan in place.

Our editorial team truly appreciates you for joining us for another weekly recap. On vacation for the 4th? You can find a recap for the week of July 1st here!

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