Thursday, July 28, 2016

FYI: CFPB Issues Outline of Potential Debt Collection Rules

Today the Consumer Financial Protection Bureau (CFPB) released an outline of its proposals for rules under the federal Fair Debt Collection Practices Act.

 

The CFPB's outline displays its intention to issue rules not only covering these third-party debt collectors and debt purchasers, but also to regulate the debt collection activities of original creditors themselves under the Bureau's authority from the Dodd-Frank Act to issue regulations prohibiting unfair, deceptive, and abusive acts and practices.

 

The outline addresses proposals intended to ensure the accuracy and integrity of information and documents used in the debt collection process, as well as providing model notices for the delivery of consumer disclosures required by the FDCPA.

 

A copy of the CFPB's outline of proposals is available at:  http://files.consumerfinance.gov/f/documents/20160727_cfpb_Outline_of_proposals.pdf

 

Substantiation of Indebtedness

 

The proposed rules could require debt collectors to "substantiate" a debt before initiating the collection process. Substantiation would require three steps: (1) obtaining "fundamental information;" (2) the debt owner's written representation of accuracy; and, (3) monitoring that there are no "warning signs" attributable to the account.

 

'Fundamental Information'

 

The Bureau may propose that debt collectors have "fundamental information" before commencing collection. The "fundamental information" would include the following:

 

- The full name, last known address, and last known telephone number of the consumer;

- The account number of the consumer with the debt owner at the time the account went into default;

- The date of default, the amount owed at default, and the date and amount of any payment or credit applied after default;

- Each charge for interest or fees imposed after default and the contractual or statutory source for such interest or fees; and

- The complete chain of title from the debt owner at the time of default to the collector.

 

The proposal would not require a debt collector to obtain every item and would allow the debt collector to substantiate indebtedness through alternative or additional information. In that case, a debt collector would "bear the burden of justifying its alternative approach."

 

Representation of Accuracy

 

In addition to obtaining the specified information, a debt collector would need to obtain a "written representation" from the debt owner that "it has adopted and implemented reasonable written policies and procedures to ensure the accuracy of transferred information and that the transferred information is identical to the information in the debt owner's records." Failure to obtain the written representation would not prohibit collection, but the debt collector would again bear the burden of justifying its alternative approach.

 

Review for 'Warning Signs'

 

The final step in substantiation would require a debt collector to review both the account being collected and, if applicable, the "portfolio," for warning signs that would "raise questions" concerning the accuracy or integrity of the information provided by the debt owner concerning either a particular account or the entire portfolio. With respect to an account, this would be information that is not in a "clearly understandable form" or is "facially implausible or contradictory." Across a portfolio, a significant portion of the accounts have missing or "implausible information," or a "significant percentage" of the accounts have unresolved disputes.

 

If a warning sign is uncovered, the proposed rules may require a debt collector "to take further steps before it would be able to support and lawfully make claims of indebtedness regarding the account or the portfolio, as applicable." Such steps may include:

 

- Obtaining and reviewing supplemental information from the original creditor or prior collectors;

- Obtaining and reviewing information from other sources, such as data vendors that provide consumer contact information; and

- At the portfolio level, obtaining and reviewing documentation "for a representative sample of accounts—or in some cases, for all accounts—in the portfolio."

 

The warning sign review would make debt collectors "responsible" for undertaking an investigation in response to detected warning signs. It would not require a debt collector to "confirm all of the information" it receives.

 

Impact on Persons Not Subject to FDCPA

 

The Bureau stated the proposed rules will not require persons not presently subject to the FDCPA to provide information "when they sell or transfer a debt." But it will consider imposing such a rule "in the future."

 

Monitoring Collection Process for 'Warning Signs'

 

The rules may require debt collectors to monitor their collection efforts for the appearance of "warning signs" and to undertake specific actions when they appear. These "warning signs are: (1) a consumer dispute "with respect to an individual debt"; (2) a debt collector's "inability to obtain documents" in response to a consumer's dispute; or (3) a debt collector's receipt of disputes for a significant percentage of a portfolio as compared to similar debt types.

 

Unlike current law, which requires a debt collector to respond to a written dispute received within 30 days of its initial notice to the consumer, the rules would expand a dispute to both written and oral disputes received at any time, including complaints made in litigation.

 

Debt Subject to a Statute of Limitations Defense

 

The proposed rules would require new disclosures with respect to any debt subject to a statute of limitations defense. As proposed, the rules would require a simple statement that the debt collector "cannot sue" on the debt. This statement under the vast majority of state law would be legally incorrect. The states do in fact allow such debts to be sued upon and only handfuls prohibit it.

 

Contact with Consumers – Voicemails

 

The proposed rules would allow a safe harbor for voicemails, a particularly troublesome source of frivolous litigation against compliant debt collectors. The Bureau proposes that certain voicemail disclosures would not violate the FDCPA. The proposed disclosure would state: (1) the individual debt collector's name; (2) the consumer's name; and (3) a toll-free method that the consumer can use to reply to the collector.

 

The outline even proposes a compliant script: "This is John Smith calling for David Jones. David, please contact me at 1-800-555-1212."

 

The Bureau states "[t]his would allow collectors to leave such limited-content messages in a voicemail message, with a third-party in a live conversation, or through another method of communication (e.g., in a text message or an email), without triggering the requirement to provide the FDCPA warnings . . . If the collector succeeds in reaching the consumer or if the consumer contacts the collector after receiving the message, these FDCPA requirements would apply immediately."

 

Contact with Consumers – Frequency of Telephone Calls

 

The proposed rules would limit the number of calls made to consumers on a weekly basis. Where the debtor is confirmed, the total contact would be limited to twice a week to the same contact number or three times a week to all contact numbers. Where the contact has not been confirmed, the number of contacts would be limited to three per contact or a total of six for all contact points.

 

Attempts to contact third parties would count to the cap. These caps would likely discourage calls when repossession of a vehicle or foreclosure proceedings were contemplated. It would likely behoove the debt collector to move forward with taking the collateral than run afoul of the proposed contact limitations.

 

Contact with Consumers – Making of Telephone Calls

 

The Bureau proposes a rule that would make it impermissible to contact a consumer if the consumer stated something to the effect of "I cannot talk on the phone about this." In that event, the debt collector must ask the consumer if a different time or place for the call would be acceptable. If the consumer does not provide a different time or place then "the collector thereafter would be limited to contacting the consumer using methods other than calls."

 

Contact with Consumers – Workplace Emails

 

A debt collector could communicate with a debtor using the debtor's "work email . . . if the consumer specifically consented to being contacted at his or her work email." Such consent can be provided directly from the debtor or the debtor may provide the email address "in a communication with the collector as a place to which to send return emails."

 

For example, if a consumer emailed a collector from "a certain email address," which happened to be the debtor's work email address, the debt collector can deem that as "consent to use that email address for future communications so long as the content of the email did not convey otherwise."

 

Form Validation Notices

 

The proposed rules would include a model notice that would provide consumers with the information required under section 1692g of the FDCPA. Use of the model notice would be deemed as indicative of compliance with section 1692g.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Indiana   |   Maryland   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments

 

and

 

Insurance Recovery Services

 

 

FYI: Nevada Fed Ct Denies Class Cert on "Ascertainability" Grounds, Confirms Fannie/Freddie Liens Not Extinguished by HOA Foreclosure

The U.S. District Court for the District of Nevada recently confirmed that a homeowner association's foreclosure of its superpriority lien cannot extinguish a property interest of Fannie Mae or Freddie Mac while those entities are under the Federal Housing Finance Agency's (FHFA) conservatorship.

 

In so ruling, the Court also denied class certification, holding that the issue of whether Fannie Mae or Freddie Mac held an interest in the property at issue at the time of a homeowners association foreclosure sale presents an impermissible individualized factual inquiry that would require "mini-trials" as to each affected property.

A copy of the opinion is available at:  Link to Opinion

 

As you may recall, in July of 2008, the Federal Housing Finance Agency was tasked by Congress to regulate Fannie Mae, Freddie Mac, and the twelve Federal Home Loan Banks.  In so doing, Congress granted the FHFA among other things a statutory "exemption" providing that when the FHFA acts as conservator of Fannie Mae or Freddie Mac, "[n]o property of [FHFA] shall be subject to levy, attachment, garnishment, foreclosure, or sale without the consent of [FHFA], nor shall any involuntary lien attach to the property of [FHFA]." 12 U.S.C. § 4617(j)(3).

 

In September 2008, FHFA placed Fannie Mae and Freddie Mac into conservatorships for the purpose of reorganizing or rehabilitating them. FHFA succeeded to all rights, titles, powers and privileges of Fannie Mae and Freddie Mac.

 

Fannie Mae and Freddie Mac acquired separate ownership interests in each of the five properties in the instant case (Properties), prior to a homeowners association (HOA) foreclosure sale through which the HOAs purchased the Properties.

 

The FHFA, Fannie Mae, and Freddie Mac filed this putative class action seeking to have their interests in certain properties subject to HOA foreclosures adjudicated as against three HOA defendants.  Four motions were before the Court:  the HOA defendants' Motion to Dismiss, the FHFA plaintiffs' Motion for Summary Judgment, the FHFA plaintiffs' Motion to Certify Class, and the HOA defendants' Motion to Sever. 

 

HOA Defendants' Motion to Dismiss

 

As noted above, 12 U.S.C. § 4617(j)(3) provides that while FHFA acts as conservator of Fannie Mae and Freddie Mac, "[n]o property of the Agency shall be subject to levy, attachment, garnishment, foreclosure, or sale without the consent of the Agency, nor shall any involuntary lien attach to the property of the Agency."

 

Nevada Revised Statutes §116.3116 states "the association has a lien on a unit for any construction penalty that is imposed against the unit's owner pursuant to NRS 116.310305, any assessment levied against that unit or any fines imposed against the unit's owner from the time the construction penalty, assessment or fine becomes due…"

 

The District Court previously held in Skylights LLC v. Byron, 112 F. Supp. 3d 1145 (D. Nev. 2015), that 12 U.S.C. §4617(j)(3) prohibits property of FHFA from being subject to a foreclosure without its consent, even if such foreclosure sale is held by an HOA pursuant to Nevada Revised Statutes § 116.3116.

 

The Court upheld its prior ruling in Skylights LLC, and denied the HOA's Motion to Dismiss.  The Court reached its holding on different grounds in this case, but found no reason to overturn its prior holding in Skylights.

 

FHFA Plaintiffs' Motion for Summary Judgment

 

The FHFA plaintiffs requested that the Court declare that (1) 12 U.S.C. § 4617(j)(3) preempts any Nevada law that would permit a foreclosure on a superpriority lien to extinguish a property interest of Fannie Mae or Freddie Mac while they are under FHFA's conservatorship, (2) the HOA Sale did not extinguish the plaintiffs' interest in the Properties and thus did not convey the Properties free and clear to any Defendants, and (3) title to the Properties is quieted in either Fannie Mae's or Freddie Mac's favor insofar as the Defendants' interest, if any, is subject to the interest of the plaintiffs or, if applicable, the interest of the plaintiffs'  successors.

 

Returning to its holding in Skylights LLC, the Court held that the plain language of 12 U.S.C. §4617(j)(3) prohibits property of FHFA from being subject to a foreclosure without its consent.

 

The Court found that the FHFA had an interest in each of the Properties prior to the HOA foreclosure sales.  The Court then held that §4617(j)(3) prevents the HOA's foreclosure on the Properties from extinguishing the deeds of trust of the Properties as FHFA held an interest in the deeds as conservator for Freddie Mac and Fannie Mae prior to the HOA foreclosures.

 

Accordingly, the FHFA plaintiffs' motion for summary judgment was granted.

 

FHFA Plaintiffs' Motion to Certify Class

 

The Court recited that a party seeking class certification must prove that the class is "ascertainable," meaning that membership in the class can be determined by reference to objective criteria.

 

Here, the FHFA plaintiffs defined the proposed class as a defendant class of "current record owners—other than Fannie Mae, Freddie Mac, or the Conservator—of Units as to which: (1) HOA Foreclosure Sales have been or will be completed on or after September 18, 2009, (2) an Enterprise Lien had attached and had not been satisfied at the time of the applicable HOA Foreclosure Sale, and (3) the Court may assume and exercise in rem jurisdiction."

 

The HOA defendants argued that the merits of the FHFA plaintiffs' action hinges on the extent to which the FHFA plaintiffs owned an "Enterprise Lien," and therefore that the merits of the case are impermissibly implicated by class definition.

 

The District Court agreed with the HOA defendants and held that the issue was impermissibly dependent on a highly individualized fact inquiry. Thus, the Court held, the proposed class is not reasonably ascertainable. Accordingly, the Court denied the plaintiffs' Motion to Certify Class.

 

HOA Defendants' Motion to Sever

 

As you may recall, Rule 20(a)(2) of the Federal Rules of Civil Procedure provides that, in order for more than one defendant to be joined together in an action, the defendants must meet two specific requirements: (1) the right to relief asserted against each defendant must arise out of or relate to the same transaction or occurrence or series of transactions or occurrences; and (2) a question of law or fact common to all defendants must arise in the action. If the test for permissive joinder is not satisfied, a court, in its discretion, may sever the misjoined parties, so long as no substantial right will be prejudiced by the severance.

 

Here, the Court noted that although each of the HOA defendants purchased the Properties at HOA foreclosure sales, those separate, but similar, events did not constitute a series of transactions or occurrences. Thus, the Court held that severance of the misjoined HOA defendants was proper. Under the Court's ruling, the first named HOA defendant remained while the subsequent HOA defendants were dismissed without prejudice.

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia   |   Illinois   |   Indiana   |   Maryland   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments

 

and

 

Insurance Recovery Services

 

 

 

 

Wednesday, July 27, 2016

FYI: Mass SJC Holds Recorded Attorney's Affidavit May Cure Defect in Certificate of Acknowledgment for Mortgage

In response to a request from the U.S. Court of Appeals for the First Circuit, the Supreme Judicial Court of Massachusetts recently held that a recorded attorney's affidavit attesting to the proper acknowledgment of a recorded mortgage with a Certificate of Acknowledgment that omits the mortgagors' names, in certain circumstances, may cure the defect in the Acknowledgment.

 

The Court also held that a recorded attorney's affidavit attesting to the proper acknowledgment of a recorded mortgage with a Certificate of Acknowledgment that omits the mortgagors' names, in certain circumstances, may provide constructive notice of the existence of the mortgage to a bona fide purchaser in combination with the mortgage.

 

A copy of the opinion is available at: Link to Opinion

 

Two borrowers obtained a refinance mortgage loan. The borrowers initialed the bottom of each page of the mortgage and signed the signature page. Their attorney also signed the signature page as a witness.

 

The mortgage contained a Certificate of Acknowledgement on a separate page. The borrowers initialed this page, but the space left open to enter the names of the persons appearing before the notary public was left blank. The acknowledgement was notarized and the mortgage was recorded.

 

The borrowers' attorney later recorded an affidavit stating that through inadvertence, the names of the debtors who executed the mortgage were omitted from the notary clause. The attorney attested to witnessing them execute the mortgage voluntarily. 

 

Some six months later, the borrowers filed a Chapter 7 Bankruptcy. The bankruptcy trustee filed an adversary complaint seeking to avoid the mortgage, arguing that the omission of the borrowers' names on the Certificate of Acknowledgment was a material defect. The mortgagee moved for summary judgment arguing that the defect was cured with the attorney's affidavit.

 

The Bankruptcy Court granted summary judgment in favor of the bankruptcy trustee.  The trial court reversed and granted summary judgment to the mortgagee. The bankruptcy trustee then appealed to the First Circuit which concluded that a proper resolution of the appeal turned on undecided issues of Massachusetts law, and certified the issues to the Supreme Judicial Court of Massachusetts.

 

As you may recall, under Massachusetts law, "title to real estate may be transferred by a deed which has not been acknowledged or which contains a certificate showing a defective acknowledgement, and the deed is good against the grantor and his heirs and those having actual notice, G. L. (Ter. Ed.) c. 183, § 4, but the grantor must acknowledge that he has executed the instrument as his free act and deed, and a certificate reciting that the grantor appeared before the officer making the certificate and made such acknowledgment must be attached to the instrument in order to entitle it to be recorded, G. L. (Ter. Ed.) c. 183, § 29, in order that notice of the conveyance shall be given to all the world.  The certificate of acknowledgment furnishes formal proof of the authenticity of the execution of the instrument when presented for recording."  The Court noted that this statute -- G. L. c. 183, § 4 -- applies to mortgages, even though mortgages are not specifically mentioned.

 

In addition, Massachusetts General Laws c. 183, §29 states, "no deed shall be recorded unless a certificate of its acknowledgement or of the proof of its due execution, made as hereinafter provided, is endorsed upon or annexed to it, and such certificate shall be recorded at length with the deed to which it relates."  The Court noted that the reason for requiring an acknowledgement is to ensure that public notice of the transfer of title of the land in the record is accurate.

 

The first certified issue was whether an attorney's affidavit, executed and recorded pursuant to G. L. c. 183, § 5B and attesting to the proper acknowledgment of a recorded mortgage that, as originally executed and recorded, omitted the name of the mortgagor from the acknowledgement may correct the material defect.

 

The bankruptcy trustee argued three points.

 

First, the bankruptcy trustee argued the principle of functus officio prohibits a public official from unilaterally recording what essentially constitutes a formal re-acknowledgement of the mortgage agreement without the assent of the borrowers. The term "functus oficio" meant that "because of identified actions taken by one or more relevant parties, a particular pleading (e.g., a writ) or document with legal significance (e.g., a note or mortgage) was of no further legal effect and could not be the basis of any subsequent legal action."  More recently, however, the Court noted that the terms has been applied "as meaning "that an arbitrator is without power to modify his final award except where the controlling statute or 563*563 the parties authorize modification." The Court held that it doubted that the principle would be recognized outside an arbitration context.  Regardless, the Court held, when the requirements of §5B are met, they effectively supersede any continuing common-law functus officio principle.

 

The bankruptcy trustee then argued that the omission of the borrowers' name in the acknowledgement is a material defect that renders the recording of the mortgage invalid, because Massachusetts G. L. c. 184 §24 provides the sole means by which to cure a defect in an acknowledgement.

 

The Court disagreed, noting that §24 created a statute of repose to protect the chain of title to real property from attenuated challenges. However, the Court noted, nothing in the language of §24 stated or implied that it defined the exclusive permissible method of curing any and all defects that may exist in an acknowledgment.

 

The Supreme Judicial Court of Massachusetts then looked to the language of §5B to determine what types of errors relating to a defective acknowledgment may properly be corrected with an attorney's affidavit.  The Court noted that §5B requires that: (1) facts contained in the affidavit must be based on the personal knowledge of the affiant; and (2) the affidavit include a certification by an attorney that the facts stated are both relevant to the title of specifically identified property and "will be of benefit and assistance in clarifying the chain of title." The Court noted that the Legislature's choice of the word "clarifying" suggested that the attorney's affidavit must be limited to facts that explain what actually occurred, and are not inconsistent with the substantive facts contained in the original document.

 

In this case, the Supreme Judicial Court of Massachusetts held that the attorney's affidavit was sufficient to cure the defect in the acknowledgement and the recording of the mortgage. The Court noted that the defect was the omission of the borrowers' names in the Certificate of Acknowledgment, and that the attorney's affidavit supplied the missing information and confirming the execution of the mortgage was proper.

 

Lastly, the bankruptcy trustee argued that the mortgage was recorded illegally because of the defect in the acknowledgment.  The Court again disagreed, holding that the defect generally would preclude the legal recording of the mortgage, but the filed and recorded attorney's affidavit operated to cure the original defect in the acknowledgment.

 

The Supreme Judicial Court of Massachusetts then answered the second certified question -- i.e., whether an attorney's affidavit, attesting to the proper acknowledgment of a previously recorded mortgage accompanied by an acknowledgment that omitted the name of the mortgagor, may provide constructive notice to a bona fine purchaser of the existence of the mortgage, by itself or in combination with the mortgage.

 

The Court noted that, under Massachusetts law, constructive notice arises by operation of law under Massachusetts G. L. c. 183 §4, in any case where the mortgage is properly recorded, and that a mortgage recorded with a materially defective acknowledgement is not properly recorded and does not provide constructive knowledge.  However, the Court held, because the attorney's affidavit complied with §5B, "the affidavit — not by itself but in combination with that mortgage — provides legally adequate constructive notice to a bona fide purchaser or, here, a trustee in bankruptcy."

 

Accordingly, the Supreme Judicial Court of Massachusetts held that:

 

1.  "An attorney's affidavit filed pursuant to General Laws c. 183, § 5B, attesting to the proper acknowledgment of a recorded mortgage that has annexed to it an acknowledgment that omitted the mortgagors' names, in certain circumstances may cure the defect in the acknowledgment and, in turn, effectuate a proper recording of the mortgage."

 

2.  "[I]n a case in which the § 5B attorney's affidavit does cure the defect in the acknowledgment, the attorney's affidavit, considered in combination with the originally recorded mortgage, provides constructive notice of the existence of the mortgage to a bona fide purchaser; in a case where the attorney's affidavit does not cure the material defect in the acknowledgment, the affidavit, whether alone or in combination with the mortgage, does not provide constructive notice."

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Indiana   |   Maryland   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments

 

and

 

Insurance Recovery Services

 

 

Monday, July 25, 2016

FYI: Annual Consumer Financial Services Conference (CCFL :: Sept. 15-16, 2016 :: Chicago, Illinois) | Early Registration Discount Ends July 31, 2016

As a reminder, the $495 discounted registration price for this Conference will be expiring on July 31, 2016.

 

The Annual Consumer Financial Services Conference organized by The Conference on Consumer Finance Law.  The Conference will be hosted at the Loyola University Chicago School of Law, on September 15-16, 2016.

 

WHEN:  Sept. 15-16, 2016

WHERE:  Loyola University Chicago School of Law | Chicago, Illinois

CLE:  12.0 CLE Credits to Be Provided, including 1.0 hr of Ethics

PRICE:  $495 before July 31, 2016

 

 

For more information, including as to registration and hotel accommodations, please see the attached brochure, or go to:

 

https://www.ccflonline.org/conference/

 

Hope to see you there!

 

 

 

 

Ralph T. Wutscher
Maurice Wutscher LLP
The Loop Center Building
105 W. Madison Street, 18th Floor
Chicago, Illinois 60602
Direct:  (312) 551-9320
Fax: (312) 284-4751

Mobile:  (312) 493-0874
Email: rwutscher@MauriceWutscher.com

 

Admitted to practice law in Illinois

 

 

 

Alabama   |   California   |   Florida   |   Georgia  |   Illinois   |   Indiana   |   Maryland   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC

 

 

NOTICE: We do not send unsolicited emails. If you received this email in error, or if you wish to be removed from our update distribution list, please simply reply to this email and state your intention. Thank you.


Our updates and webinar presentations are available on the internet, in searchable format, at:

 

Financial Services Law Updates

 

and

 

The Consumer Financial Services Blog

 

and

 

Webinars

 

and

 

California Finance Law Developments

 

and

 

Insurance Recovery Services