Thursday, May 10, 2018

FYI: 9th Cir Rejects FDCPA Claim That Collector Did Not "Meaningfully Participate" in Collection

The U.S. Court of Appeals for the Ninth Circuit recently rejected a so-called "flat-rating" claim, holding that a company that sent letters demanding that hospital patients pay their overdue medical bills did not create a false or misleading impression that the company was actually participating in collecting the debts in violation of the federal Fair Debt Collection Practices Act (FDCPA), because the company meaningfully participated in the hospital's efforts to collect debts.

 

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

 

The plaintiff received treatment at a hospital but failed to pay the medical bills.  After the plaintiff ignored multiple requests for payment, the hospital referred her delinquent accounts to a collection agency.

 

The hospital and the collection agency operated together under a Subscriber Agreement where the hospital would refer delinquent patient accounts to the collection agency.  For a fixed fee, the collection agency would send letters requesting payment by check, credit card, or online at the hospital's website.

 

The collection agency sent three demand letters to the plaintiff.  In response to the third letter, the plaintiff disputed the debt and the collection agency marked the account as disputed and returned the account to the hospital.

 

In March 2014, the plaintiff filed a putative class action against the collection agency and hospital alleging violations of the federal Fair Debt Collection Practices Act (FDCPA), including but not limited to 15 U.S.C. §§ 1692e and 1692j.

 

The plaintiff alleged that the letters she received "created a false or misleading belief that [the collection agency] was meaningfully involved in the collection of a debt prior to the debt actually being sent to collection" -- a practice commonly known as flat-rating.

 

The hospital and collection agency moved for summary judgment.  In response to the motions, the plaintiff argued that even if her flat-rating claim failed, the defendants' practices violated 15 U.S.C. § 1692e(5) by falsely threatening to take further action against her if she refused to pay her debt.  The plaintiff argued that the collection agency had no actual authority to take any action against her outside of sending the demand letter.

 

The trial court granted the defendants' motion for summary judgment.  It ruled that the evidence established that the collection agency meaningfully participated in the collection of the plaintiff's debt, thereby precluding any flat-rating claim.  The trial court also struck the section 1692e(5) claim because it was raised too far into the litigation, plaintiff did not formally amend her complaint, and the claim was barred by the FDCPA's one year statute of limitations.

 

The plaintiff appealed and challenged the trial court's rejection of both her flat-rating and § 1692e(5) claims.  The plaintiff also argued that she had a viable claim under § 1692e(10) for the collection agency's allegedly deceptive acquisition of her information.

 

The Ninth Circuit began its analysis by reviewing the flat rating claim.

 

As you may recall, § 1692j prohibits "flat-rating -- the practice where a third party (usually for a flat rate) sells form letters to a creditor -- which creates the false impression that someone (usually a collection agency) besides the actual creditor is 'participating' in collecting the debt."  See White v. Goodman, 200 F.3d 1016, 1018 (7th Cir. 2000).  Flat-rating essentially involves a creditor using a third party's name for intimidation value.

 

Because it was undisputed that the collection agency furnished form letters to create the belief that it was participating in the collection of debts owed the hospital, the question presented to the Ninth Circuit was whether there was sufficient evidence in the record to support the plaintiff's contention that this impression was false.

 

Section 1692j does not define what it means for a person to participate in the collection of or in an attempt to collect a debt.  The statute makes it unlawful to:

 

design, compile, and furnish any form knowing that such form would be used to create the false belief in a consumer that a person other than the creditor of such consumer is participating in the collection of or in an attempt to collect a debt such consumer allegedly owes such creditor, when in fact such person is not so participating.

 

15 U.S.C. § 1692j(a).

 

The plaintiff argued that the collection agency must do more than merely mail form letters to "participate" sufficiently in debt-collection efforts.  For example, the plaintiff argued that the collection agency did not have authority to negotiate or to process payments from debtors, it received no proceeds from payments that were made, and it was not involved in any further action that was pursued against debtors whose accounts remained delinquent.

 

The Ninth Circuit noted that meaningful participation in the debt collection process may take a variety of forms.  It considered the amount of control the entity exercised over the collection letters it sends, the amount of contact the entity had with the debtors, whether the entity invited and responded to debtor inquiries, whether the entity received or negotiated payments, whether the entity received or retained full debtor files, and whether the entity was involved in further collection activities if the debt remained unpaid. 

 

Above all, the Ninth Circuit stated that the key is whether the entity genuinely contributed to an effort to collect another's debt. 

 

The Ninth Circuit found that while the collection agency did not process payments, it participated in the attempts to collect debts owed to the hospital because: (1) it independently screened accounts for barriers to collection, (2) it drafted and mailed the collection letters without input from the hospital, (3) its letters invited the debtor to contact the collection agency and its personnel handled such inquiries, (4) it in fact received approximately 500 calls a week from debtors and received hundreds of pieces of mail from debtors, (5) it provided debtors with information about the debt and how to repay them, (6) it maintained a website where debtors could access information about their debts and submit documents, and (7) it sometimes received and forwarded to the hospital payments it received from debtors.

 

Therefore, the Ninth Circuit determined that the collection agency's efforts were enough to have participated meaningfully in the attempts to collect debts like the plaintiff's.

 

The plaintiff argued that the trial court's conclusion was inconsistent with two out of circuit cases in which attorneys who mailed collection notices on a creditor's behalf were deemed not to have participated meaningfully.

 

In Nielsen v. Dickerson, the Seventh Circuit considered whether certain form collection letters falsely represented that the letters came "from an attorney" in violation of 15 U.S.C. § 1692e(3).  Nielsen v. Dickerson, 307 F.3d 623, 634-35 (7th Cir. 2002).  The question in Nielsen turned on whether the attorney who composed and mailed the letters in an "assembly-line fashion" was actually involved in the debt collection process.  Id., at 635.

 

The Ninth Circuit noted that Nielsen only briefly addressed the attorney's potential liability as a flat-rater under 1692j, stating that the attorney might "seem to be a natural candidate for flat-rating liability pursuant to section 1692j."  Id., at 639.  However, the Seventh Circuit in Nielsen ultimately did not decide whether the attorney violated section 1692j because any such liability would have been redundant to the attorney's liability under section 1692e(3).  Id., at 640.

 

Thus, the Ninth Circuit found that Nielsen did not support the plaintiff's argument.

 

In Vincent v. Money Store, the Second Circuit considered whether a creditor that hired a law firm to mail debt collection notices could be held liable for violation of section 1692e as its own debt collector under the FDCPA's false name exception, because the law firm was not meaningfully involved in collection efforts.  Vincent v. Money Store, 736 F.3d 88, 91 (2nd Cir. 2013). 

 

The Second Circuit applied the analysis in Nielsen and concluded that "a jury could find" that collection letters mailed by the law firm "falsely implied that [the firm] was attempting to collect [the creditor's] debts and would institute legal action against debts," when the firm "acted as a mere conduit for a collection process [the creditor] controlled." Id., at 104.

 

The Ninth Circuit was not persuaded by Vincent either because the collection agency in this case participated to a greater degree in collection efforts than the law firm in Vincent did.  The plaintiffs in Vincent presented evidence that the law firm drafted the letters jointly with the creditor, directed debtors to send nearly all communications to the creditor itself, and after mailing the demand letters "performed virtually no role in the actual debt collection process" besides verifying the existence of the debt or the identity of the creditor.  Id., at 93-95, 104.

 

Given the greater degree of participation by the collection agency in this case, the Ninth Circuit determined that Vincent was distinguishable and did not support the plaintiff's position.

 

Therefore, the Ninth Circuit held that the collection agency in this case meaningfully participated in the attempts to collect the plaintiff's debts.

 

Next, the Ninth Circuit turned to the plaintiff's arguments regarding the FDCPA's prohibition against "threat[ening] to take any action that cannot legally be taken or that is not intended to be taken." 15 U.S.C. § 1692e(5).

 

The plaintiff argued that her complaint gave the collection agency adequate notice of its need to defend against the claim, and even if it did not, she should have been given leave to amend the complaint.

 

However, the Ninth Circuit found that the plaintiff's complaint focused narrowly on her flat-rating allegations.  It never cited § 1692e(5) and did not mention the FDCPA's prohibition against threatening to take an action that is not intended or legally authorized.  And, the Ninth Circuit found that the complaint expressly disavowed such a claim by alleging that the collection agency "was not acting as a debt collector when it sent the Letters."

 

Because the plaintiff's theory of liability was that the collection agency was a flat-rater, not a true debt collector, the Ninth Circuit held that the trial court did not err in striking the claim.

 

The plaintiff further argued that she should have been granted leave to amend the complaint, and the amended claim should "relate back" to the date of her original complaint.

 

The Ninth Circuit rejected this argument because an amended complaint relates back to the date of the original complaint only where the claim arose out of the same conduct in the original pleading. 

 

The plaintiff's § 1692e(5) claim, in the Ninth Circuit's view, would not rely on the same facts and evidence because the plaintiff complaint did not allege (1) that the collection agency was a debt collector, and (2) that the collection agency threatened to take any action against her that it had no authority or intention to take.  These issues, according to the Ninth Circuit, would involve different witnesses and the trier of fact would need to determine what, if anything, the collection letters threatened to do.

 

Additionally, the Ninth Circuit determined that the plaintiff waived her claim under § 1692e(10) because the claim in nowhere to be found in the complaint, and she did not argue the claim in opposing the defendants' motions for summary judgment.

 

Accordingly, the Ninth Circuit affirmed the trial court's grant of summary judgment in favor of the defendants.

 

 

 

 

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

 

 

 

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Tuesday, May 8, 2018

FYI: Fla App Ct (4th DCA) Holds RIC Not Subject to State Usury Law

The District Court of Appeal of the State of Florida, Fourth District ("4th DCA") recently affirmed entry of summary judgment in favor of a motor vehicle retail seller and assignee against a consumer who alleged that the 27.81% interest charge under the retail installment contract exceeded the interest rate limit imposed by the Florida's usury statute.

 

In so ruling, the 4th DCA concluded that the financing contract at issue was not subject to the interest rate limit imposed by Florida's general usury statute, but instead by the specific controlling statute, the Florida Motor Vehicle Retail Sales Finance Act.

 

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

 

In 2009, a consumer ("Consumer") purchased a used 2004 vehicle from a licensed motor vehicle retail installment seller ("Seller").  The retail installment sales contract (the "RIC") entered between Consumer and Seller at purchase stated that the buyer may purchase for cash or credit, subject to certain financing terms, including an express disclosure that "[w]e will figure your finance charge on a daily basis at the Base Rate of 27.81% per year.  The Truth-In-Lending Disclosures are part of this contract."  The federal Truth-In-Lending ("TILA") disclosures appeared on the first page of the RIC.

 

The RIC was later assigned to a sales finance company ("Assignee"), as expressly permitted under its terms.

 

The Consumer filed in suit in Florida state court against the Assignee and two of its employees, and later added the Seller as a fourth defendant in her third amended complaint.  The Consumer alleged that the 27.81% interest charge under the RIC exceeded the 18% interest rate limit imposed by Florida's usury statute, and included five counts for criminal usury and alleging violations under Chapter 772, Florida Statutes (2009), the Civil Remedies for Criminal Practices Act. Chapter 772.101, Fla. Stat. (2009).

 

The Seller and Assignee moved for summary judgment, which was granted in their favor and against the Consumer in the trial court.  The trial court concluded that the RIC was not subject to Florida' general usury statute and that the Consumer's sworn statements and witness depositions failed to raise a genuine issue of material fact.

 

This appeal followed.

 

As you may recall, under Florida law, usury requires proof of four elements: (1) an express or implied loan; (2) a repayment requirement; (3) an agreement to pay interest in excess of the legal rate; and (4) a corrupt intent to take more than the legal rate for the money loaned. Oregrund Ltd. P'ship v. Sheive, 873 So. 2d 451, 456 (Fla. 5th DCA 2004). The buyer, as the party claiming usury, has the burden of establishing its elements. Video Trax, Inc. v. NationsBank, N.A., 33 F. Supp. 2d 1041 (S.D. Fla. 1998).

 

The Appellate Court first examined the dispute over the third element, the "legal rate of interest."

 

Under the Florida usury statute, interest exceeding 18% is usurious. § 687.02, Fla. Stat. (2009). Therefore, the usury statute conflicts with the Florida Motor Vehicle Retail Sales Finance Act, which allows the imposition of higher interest rates.  The Consumer argued that the applicable legal rate of interest that applied to the RIC was set forth in Florida's usury statute, Chapter 687, Florida Statutes (2009), while the Seller and Assignee argued that the RIC was a retail installment sales contract pursuant to Chapter 520, Florida Statutes, and therefore was not subject to Florida's general usury statute.

 

The 4th DCA agreed with the trial court that the RIC was, in fact, a retail installment sales contract, and that the Seller and Assignee were permitted to charge the interest rate permitted by the Florida Motor Vehicle Retail Sales Finance Act based upon undisputed evidence that: (i) the title of the RIC stated "Retail Installment Sale Contract" in bold; (ii) the RIC complied with statutory requirements and included the requisite "notice to buyer" and separate written itemization of amount financed; (iii) the RIC's terms fit within the statutory definition; (iv) the Seller and Assignee were licensed under the Florida Motor Vehicle Retail Sales Finance Act, and the Consumer met the definition of a buyer as defined under the Florida Motor Vehicle Retail Sales Finance Act, and; (v) the parties' conduct supported the trial court's finding that the RIC was a retail installment sales contract.

 

As the undisputed interest rate of 27.810% did not exceed the finance charge permitted by § 520.08 Fla. Stat. on the unpaid balance, it was permissible under the Florida Motor Vehicle Retail Sales Finance Act.  See Chapter 520.085, Fla. Stat. (2009).

 

The Appellate Court acknowledged that both the Florida usury statute (Chapter 687, Fla. Stat.) and the Florida Motor Vehicle Retail Sales Finance Act (Chapter 520, Fla. Stat.) embrace the same subject (allowable interest rates) and produce contradictory results (what is usurious under Chapter 687 is permissible under Chapter 520).  However, under established Florida law and basic statutory principles, when two statutes appear to conflict, a specific statute (in this case Chapter 520) will control over a general statute (Chapter 687).  See Fla. Virtual Sch. C. K12, Inc., So. 3d 97, 102 (Fla. 2014); Lunohah Invs., LLC v. Gaskell, 158 So. 3d 619, 621 (Fla. 5th DCA 2013).

 

Accordingly, the 4th DCA concludes that the Seller and Assignee were entitled to entry of summary judgment because the interest charged did not exceed the permissible rate allowed under Florida Motor Vehicle Retail Sales Finance Act and the RIC was therefore not usurious under the Florida usury statute.

 

Next, the Appellate Court examined whether or not the subject transaction constituted  a "loan" under the usury statute, which expressly applies only to "contracts for the payment of interest upon any loan, advance of money, line of credit, or forbearance to enforce the collection of a dent.  Chapter 687.02(1), Fla. Stat. (2009).

 

As to this issue, the 4th DCA agreed that summary judgment was further warranted in the Seller and Assignee's favor, because the RIC was not a "loan" under the usury statute pursuant to well-established Florida law that contracts to secure the price of property sold are not governed by general usury laws.  Perry v. Beckerman, 97 So. 2d 860, 862 (Fla. 1957) (citing Davidson, 52 So. at 139 (contract for sale of land); Scarritt Motors, 48 So. 2d at 168 (contract to purchase used car "not amenable to the charge of usury."); see also B&D Inc. of Miami v. E-Z Acceptance Corp., 186 So. 2d 29 (Fla. 3d DCA 1966) (retail installment sales contracts for used motor vehicles "are not subject to the general usury statutes"); Taylor v. First Nat'l Bank of Miami, 270 So. 2d 379 (Fla. 3d DCA 1972)(same).

 

Lastly, the 4th DCA briefly addressed the Consumer's argument  that the words "Chapter 520" were required to appear on the face of the RIC to exempt the agreement from the usury statute, pursuant to the "parity exception," Chapter 687.12, Fla. Stat.

 

As you may recall, the Florida "parity exception" permits licensed lenders to take advantage of interest rates permitted by a difference class of licensed lender so long as the lender complies "with all the requirements imposed on such a lender for the type of loan it is making," and indicates on the instrument the "specific chapter of the Florida Statutes authorizing the interest rate charged."  South Pointe Dev. Co. v. Capital Bank, 574 So. 2d 939, 941 (Fla. 3d DCA 1991)(quoting Fla. Stat. 687.12(4)).

 

Here, the parity exception did not apply to the RIC because the Seller was licensed under Florida Motor Vehicle Retail Sales Finance Act and entitled to enjoy the "rights and privileges of said statue" by virtue of its license — including the right to charge interest in a higher amount even where that interest rate exceeds the amount permitted by the usury statute.  The Appellate Court noted that only lenders "making loans.. at a rate of interest that, but for this section would not been authorized" are required to indicate on the instrument "the specific chapter of the Florida Statutes authorizing the interest rate charged."  687.12(4), Fla. Stat. (2009).

 

Accordingly, summary judgment in favor of the Seller and Assignee was affirmed.

 

 

 

 

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   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC   |   Wisconsin

 

 

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Sunday, May 6, 2018

FYI: 7th Cir Holds RESPA's QWR Provisions Require Actual Damages Caused by the Violation

The U.S. Court of Appeals for the Seventh Circuit recently affirmed a trial court's finding that a servicer did not violate the federal Real Estate Settlement Procedures Act ("RESPA") because the borrower could not prove that the servicer's failure to respond to a "Qualified Written Request" ("QWR") caused her actual damages, as required by 12 U.S.C. § 2605(f)(1)(A).

 

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

 

In 2004, a borrower ("Borrower") bought a home with the help of a mortgage loan.  Borrower lived in the home with her ex-husband, their children, and her parents. In June 2013, Borrower moved out of the home and stopped paying the loan. By May 2014 the house was unoccupied. Thieves vandalized the unoccupied home. In 2014 Borrower remarried and then subsequently divorced her new husband.

 

In March 2014, the Servicer initiated foreclosure proceedings. The foreclosure court entered a default judgment and later vacated it in June 2015 at Borrower's request.

 

The 2014 theft produced insurance money.  The servicer of the mortgage loan ("Servicer") held the insurance proceeds in escrow pursuant to the mortgage. The Borrower hired a contractor to repair the home.

 

In October 2014 Borrower saw a property-preservation company that she did not hire remove items from the home.  The Borrower took no action regarding this incident.

 

In 2015, the Servicer disbursed $10,000 from the insurance proceeds to pay for the repairs. In April 2015 the contractor abandoned the job.  The contractor feared that the Borrower would not pay for all the work.  In the spring of 2015 vandals twice more damaged the house and in June 2015 a storm damaged the roof. Borrower did not hire a new repair contractor or ask the Servicer to disburse additional insurance funds. 

 

In July 2015 the City of Indianapolis notified Borrower that the home was a nuisance and demanded that she secure and repair the home to code.  Borrower spent about $5,000 responding to the City's demands. In August 2015, Borrower began getting treatment for depression and anxiety.

 

Subsequently, on September 5, 2015 Borrower sent a letter to the Servicer inquiring about the status of the loan and the insurance proceeds.  On September 25, 2015, the Servicer responded to the letter.  Borrower claimed that she did not receive the Servicer's response and filed suit alleged that the Servicer violated RESPA.  Borrower claimed that the Servicer's failure to respond caused her economic and emotional distress damages.

 

The trial court treated the letter as a "Qualified Written Request", 12 U.S.C. § 2605(e)(1)(B), and assumed that the Servicer must ensure that the Borrower receives its response.

 

The trial court nevertheless entered judgment in favor of the Servicer and against the Borrower because she could not prove actual damages, as required by 12 U.S.C. s2605(f)(1)(A). Specifically, the trial court concluded that not receiving the Servicer's response did not cause or aggravate any of Borrower's claimed damages. This appeal followed.

 

On appeal, the Seventh Circuit observed that RESPA "requires a servicer to correct errors in its records (s2605(e)(2)(A)) or provide appropriate information if no error needs fixing (s2605(e)(2)(B), (C))."  The Seventh Circuit also noted that RESPA requires a "servicer to refrain, for 60 days, from taking steps that would jeopardize the borrower's credit rating." 12 U.S.C. s2605(e)(3).  However, the Borrower did not allege that the Servicer damaged her credit rating.  Instead, the Borrower claimed that the Servicer's failure to respond to her QWR caused her emotional distress and broke up her marriage.

 

The Seventh Circuit noted that the trial court's assumption that the servicer must ensure that the borrower receives its response "is questionable given 12 C.F.R. § 1024.11, which says that mailing a timely and properly addressed response satisfies the Act whether or not the response is received. (The statute is silent on this issue.)"

 

Regardless, even if the Servicer were required to ensure deliver of its response, the Seventh Circuit found that the Borrower could not demonstrate how earlier access to the Servicer's description of her account would have helped her or how the Servicer's "lack of an adequate response, as opposed to the ongoing foreclosure and need of money for repairs, could have contributed to her mental issues."

 

Further, the Seventh Circuit held, the alleged breakdown of the Borrower's marriage was "outside the scope of" RESPA.  Perron v. J.P. Morgan Chase Servicer, N.A., 845 F.3d 852, 858 (7th Cir. 2017) ("the breakdown of a marriage is not the type of harm that faithful performance of RESPA duties avoids").

 

Moreover, the Seventh Circuit recognized that only the Borrower's divorce from her second husband occurred after the Servicer failed to respond to her QWR.  However, the events that caused the divorce predated the Borrower's letter to the Servicer.  As such, the Court held, the Servicer's alleged lack of a response to the Borrower's QWR did not proximately cause the Borrower's divorce.

 

The Borrower argued that the Servicer's alleged failure to respond to her QWR "aggravated her problems." Specifically, the Borrower claimed she "began to feel more anxious and depressed as [she] watched [her] home continue [to] deteriorate."  However, the Seventh Circuit noted, although the lack of insurance proceeds disbursed may have caused these alleged problems if the Borrower could not afford to repair the home, the Servicer's failure to respond to the QWR did not cause this situation because RESPA "does not require a servicer to pay money in response to a written request."

 

Finally, the Seventh Circuit observed that focusing on federal rules can distract lawyers "from the more mundane doctrines of state law that may offer greater prospect of success."  Here, the contract between Borrower and the Servicer governed how the Servicer must handle and disburse insurance proceeds. RESPA, in contrast, "does not require servicers to explain the details of contracts (or contract law) to customers or their lawyers." State contract law also controlled the deal between Borrower and the repair contractor, including any available remedy. The Court noted that State law doctrines like conversion, replevin, and trespass also may have provided relief against the property preservation company.

 

Here, the Seventh Circuit held that the trial court properly determined that the Borrower's sole claim that the Servicer failed to properly respond to her QWR failed for lack of damages.  The Seventh Circuit therefore affirmed the trial court's ruling.

 

 

 

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   |   Massachusetts   |   New Jersey   |   New York   |   Ohio   |   Pennsylvania   |   Texas   |   Washington, DC   |   Wisconsin

 

 

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