Search
ACH Operations Bulletin #2-2013: High-Risk Originators and Questionable Debit Activity (Mar. 14, 2013)
Note: This Bulletin was replaced by ACH Operations Bulletin #1-2014: Questionable ACH Debit Origination: Roles and Responsibilities of ODFIs and RDFIs (Sept. 30, 2014).
Sample Co-Counsel Agreement in Class Action
This is a sample co-counseling agreement between two law firms. It covers general cooperation and terms, attorney fees under a fee-shifting award or a common fund recovery, costs and expenses, right to terminate the agreement, and appeals and separate legal actions.
ACH Operations Bulletin #3-2013, Reinitiation of Returned Debit Entries (July 15, 2013)
Note: This Bulletin was replaced by ACH Operations Bulletin #1-2014: Questionable ACH Debit Origination: Roles and Responsibilities of ODFIs and RDFIs (Sept. 30, 2014).
FTC Enforcement Policy Statement Regarding Negative Option Marketing, 86 Fed. Reg. 60,822 (Nov. 4, 2021)
The FTC policy statement provides guidance regarding its enforcement of various statutes and FTC regulations addressing negative option marketing and operating.
Letter from Consumer Groups to FHFA re Treatment of Credit Reporting Disputes
This is a November 14, 2014, letter from a number of consumer groups and law firms representing consumers to the Director of FHFA concerning the fact that that Fannie Mae’s and Freddie Mac’s then current guidelines regarding the treatment of credit reporting disputes impinges on the rights of consumers under the Equal Credit Opportunity Act (ECOA). More importantly, lenders who reject applicants because of disputed tradelines because they are unwilling to manually underwrite the loan appear to be directly violating the ECOA.