FYI: 11th Cir Confirms Providing Cell Number Gives "Prior Express Consent" Under TCPA

The U.S. Court of Appeals for the Eleventh Circuit recently held that a putative class action plaintiff provided his "prior express consent" under the federal Telephone Consumer Protection Act (TCPA) by listing his cell phone number on an information sheet he provided to the caller.

 

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

 

The plaintiff donated blood plasma in return for payment at a blood plasma collection center owned and operated by the defendants, who buy and resell blood products. The plaintiff filled out several documents incident to the donations, including and information sheet that asked for his telephone number.

 

More than two years later, one of the defendants send the plaintiff two text messages advertising the blood plasma-for-pay services.

 

The plaintiff sued, arguing that sending the text messages violated the TCPA's prohibition on using an automated telephone dialing system to dial telephone numbers without the prior express consent of the called party.

 

The defendants moved to dismiss, arguing that by providing his telephone number on the information sheet, the plaintiff gave his express consent to receive the text messages.

 

The district court granted the motion to dismiss, concluding that it lacked subject matter jurisdiction under the Hobbs Act to entertain the plaintiff's argument that the Federal Communications Commission (FCC) interpretation of the Act's "prior express consent" requirement was wrong. The plaintiff appealed.

 

As you may recall, the Hobbs Act provides that federal courts of appeals have "exclusive jurisdiction to enjoin, set aside, suspend (in whole or in part), or to determine the validity" of the FCC's regulatory interpretations.

 

The Eleventh Circuit noted that the FCC has made it clear that the prohibition against auto-dialed calls under the TCPA applies to both voice calls and text message calls. The Court also noted that the FCC over the years had repeatedly reiterated in different contexts that a person who knowingly provides his or her phone number has given prior express consent to call that number, absent instructions to the contrary.

 

The Court then analyzed whether the district court correctly held that it lacked jurisdiction under the Hobbs Act to review the FCC's interpretations of the meaning of prior express consent. Relying on its 2014 decision in Mais v. Gulf Coast Collection Bureau, Inc., which reversed the district court's ruling that the FCC's 2008 interpretation of prior express consent was inconsistent with the TCPA's plain language because it violated the Hobbs Act prohibition on a district court review of FCC orders, the Eleventh Circuit concluded that the "district court rightly refused to consider [the plaintiff's] argument that the [1992 FCC's interpretation] was inapplicable and contrary to the plain language of the TCPA because the effect would be to 'set aside, annul, or suspend' the [FCC's interpretation] and thus a violation of the Hobbs Act."

 

The Court then considered whether the defendants' sending of the two text messages violated the TCPA as interpreted by the FCC. 

 

The Eleventh Circuit easily concluded that, based on the language of subsection 227(b)(1)(A) and FCC's interpretations of the prior express consent requirement, by providing his cell phone number on the information sheet, the plaintiff expressly consented to be contacted by the defendants at that number.

 

Because the complaint on its face indicated that the plaintiff gave his prior express consent to be called on his cell phone, the district court's dismissal 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

 

 

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FYI: Illinois Amends Collection Agency Act to Exclude Non-Bank Mortgage Servicers

As you may recall, an Illinois appellate court held in 2012 unreported opinion that mortgage servicers may be subject to Illinois Collection Agency Act, 225 ILCS 425/1, et seq. ("ICAA"), including the licensing and other requirements of the ICAA. 

 

The Court held that, "[d]epending on what a mortgage servicer does other than elicit and receive routine or timely mortgage payments and attempt to collect delinquent payments, it may or may not be a debt collector" under the ICAA.

 

A copy of the opinion is available at:  http://www.illinoiscourts.gov/R23_Orders/AppellateCourt/2012/1stDistrict/1113501_R23.pdf

 

The State of Illinois recently amended ICAA to among other things:

 

1.  Clarify that non-bank mortgage lenders and servicers, and other "entities licensed pursuant to the Residential Mortgage License Act of 1987" are exempt from the ICAA;

 

2.  Increase the scope of the ICAA to now apply to "commercial" debts, as well as "consumer" debts;

 

3.  Clarify that emails "or any other Internet communication" can constitute collection activity subject to the ICAA;

 

4.  Increase the civil penalty for unlicensed activity to $10,000 per violation;

 

5.  Clarify that "credit unions" are subject to the ICAA if they own or operate a collection agency, just like "banks" and "financing and lending institutions;"

 

6.  Clarify that entities engaged "in the business of collection of a check or other payment that is returned unpaid by the financial institution upon which it is drawn" are subject to the ICAA; and

 

7.  Extend the automatic repeal date of the ICAA to January 1, 2026.

 

The amendments became effective immediately, on August 3, 2015.

 

A copy of the Public Act is available at:

 

http://www.ilga.gov/legislation/publicacts/99/PDF/099-0227.pdf

 

 

 

 

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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FYI: INVITATION: Annual Consumer Financial Services Conference (CCFL | Nov. 19-20, 2015 | Chicago, IL)

Please join us at the Annual Consumer Financial Services Conference organized by The Conference on Consumer Finance Law, and co-sponsored by the Loyola University Chicago School of Law, along with various law firms.

 

 

REGISTRATION:  http://www.ccflonline.org/conference  (or you can use the attached to register by mail)

 

WHEN:  Nov. 19-20, 2015

WHERE:  Chicago, Illinois

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

PRICE:  $495 before Sept. 18, 2015

 

Please circulate this Invitation to any other people -- inside or outside your firm -- whom you think might be interested in attending.

 

 

The Conference will include presentations by some 45 of the best and brightest speakers and practitioners in the country, on the following topics:

 

 

TCPA: The New FCC Order

Fair Lending and HMDA

CFPB Administrative Appeals

Arbitration Developments

UDAAP

Cybersecurity

CFPB Regulation of Non-Bank Auto Finance

 

TRID: Issues and Implementation

Flood and Lender-Placed Insurance

Mortgage Servicing and Bankruptcy

 

State Regulation of Debt Collection/Debt Buyers

Credit Reporting and Bankruptcy

The Madden Case and Debt Sales

 

CFPB Regulation Through Enforcement Actions

Ethics and Professional Responsibility

 

 

Additional information is provided in the attached, and at:  http://www.ccflonline.org/conference

 

 

 

 

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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FYI: 2nd Cir Rejects Lender-Placed Insurance Overcharge Claims Under Filed Rate Doctrine

The U.S. Court of Appeals for the Second recently rejected claims by borrowers who failed to maintain hazard insurance on their mortgaged properties that they were overcharged by their loan servicer for lender-placed insurance, holding the claims were barred by the filed rate doctrine.

 

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

 

The plaintiffs, borrowers who failed to purchase hazard insurance on their homes as required by the terms of their loans, sued their loan servicer, who purchased lender-placed insurance ("LPI") from defendant insurers at rates approved by the applicable regulatory agencies, then sought to collect the cost of the LPI from the borrowers.

 

The plaintiff alleged that they were overcharged because of an alleged kickback and rebate scheme between the servicer, insurer and its affiliated management company, which supposedly violated the Racketeer Influenced and Corrupt Organizations Act ("RICO") and the Real Estate Settlement Procedures Act ("RESPA").

 

All of the defendants settled except the insurer and management company. These defendants moved to dismiss, arguing that the filed rate doctrine barred the plaintiffs' claims.

 

The district court denied the motion in part, reasoning that although the insurer had received approval for the LPI rates it charged to the servicer, that approval did not extend to the borrowers' reimbursement of the servicer for the LPI. Due to a conflict among the courts on the issue, the district court certified its decision for interlocutory appeal.

 

On appeal, the Second Circuit described the alleged scheme as consisting of an agreement by the servicer to buy LPI exclusively from the insurer and, in return, the insurer would provide the servicer with loan tracking services through its affiliated management company. The plaintiffs characterized the management company's services, which included identifying borrowers who had defaulted on their duty to maintain hazard insurance, "as, in effect, a discount on LPI from the filed rates approved by regulators." This was supposedly wrongful because the servicer billed the plaintiff borrowers for the full filed rates, while supposedly retaining the benefit of the "discount" for itself.

 

The Second Circuit explained that pursuant to the filed rate doctrine, "any 'filed rate'—that is, one approved by the governing regulatory agency—is per reasonable and unassailable in judicial proceedings brought by ratepayers." The rationale for the doctrine is that: 1) courts are ill-equipped to second-guess regulators as to approved rates, also known as the "nonjusticiability" prong or principle; and 2) litigation should not be used as a means for some ratepayers to gain preferential rates, known and the "nondiscrimination" principle. The doctrine applies to both federal and state causes of action and protects rates approved by federal or state agencies.

 

Noting that there was no dispute that the LPI rates at issue were filed with regulators and that the plaintiffs were billed for those same rates the by the servicer, the Court analyzed whether the plaintiffs' claims would violate either prong of the filed rate doctrine test.

 

Citing its own precedent, the Second Circuit noted that the nonjusticiability principle doesn't just prevent judicial rate-setting, but also "precludes any judicial action which undermines agency rate-making authority" and, accordingly, "a claim may be barred even if it can be characterized as challenging something other than the rate itself."

 

The Court reasoned that allowing plaintiffs' claims would undermine the rate-making authority of the state insurance regulators who approved the insurer's LPI rates, rejecting the plaintiffs' theory that they were overbilled when they were charged the full LPI rates instead of lower rates reflecting the value of the management company's loan tracking services, concluding that the plaintiffs' claims were barred, because under the nonjusticiability principle, "whether insurer-provided services should have been reflected in the calculation of LPI" is a question reserved for the regulators, not the courts.

 

Likewise, the Second Circuit reasoned that the plaintiffs' claims failed to pass muster under the  nondiscrimination prong because it, like nonjusticiability, applies to claims that purport to seek relief other than a lower rate, and any damages recovered by plaintiffs would, in essence, constitute a rebate, giving them preference over other borrowers who were charged the full LPI filed rate. The Court pointed out that this problem of preferential discrimination was not overcome because the plaintiffs sued on behalf of a putative class.

 

The Second Circuit specifically noted that it disagreed with the district court's conclusion that the filed rate doctrine did not apply at all because it applies only when an insurer deals directly with the ratepayer, not when the insurer bills the lender, who in turn bills the borrower.

 

The Court concluded that the "filed rate doctrine is not limited to transactions in which the ratepayer deals directly with the rate filer. The doctrine operates notwithstanding an intermediary that passes along the rate," reversing and remanding with directions to dismiss the case.

 

 

 

 

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

 

 

CALIFORNIA   |   FLORIDA   |   ILLINOIS   |   INDIANA   |   NEW JERSEY   |   NEW YORK   |   OHIO   |   PENNSYLVANIA   |   TEXAS   |   WASHINGTON, D. C.

 

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

 

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and

 

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and

 

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Insurance Recovery Services

 

 

 

 

FYI: DC Cir Holds Bank Has Standing to Challenge Constitutionality of CFPB, But Not FSOC's "Too Big to Fail" Authority

The U.S. Court of Appeals for the District of Columbia Circuit recently held that a bank has standing to challenge the constitutionality of the federal Consumer Financial Protection Bureau and the recess appointment of its director, reversing the district court and remanding.

 

However, the Court also held that the plaintiff bank lacked standing to challenge the constitutionality of the federal Financial Stability Oversight Council and the government's authority to liquidate "too big to fail" financial companies, affirming the district court's judgment on those claims.

 

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

 

The plaintiff bank joined by a group of states filed suit in the U.S. District Court for the District of Columbia, challenging the constitutionality of the following parts of the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd Frank Act"): 

 

1) the Dodd Frank Act's creation of the Consumer Financial Protection Bureau, arguing that an independent agency like the CFPB cannot be headed by one person and Congress' broad delegation of authority to the CFPB violates the "non-delegation doctrine;"

 

2) President Obama's recess appointment of the CFPB's director, because it occurred during a Senate recess of insufficient length;

 

3) the Dodd Frank Act's creation of the Financial Stability Oversight Council and its authority to designate certain financial companies as "too big to fail," arguing that this violates the non-delegation and separation of powers doctrines because the FSOC has unfettered power to decide which companies should face additional regulation; and

 

4) the Dodd Frank Act's grant to the Treasury, Federal Reserve and FDIC of the authority to liquidate failing financial companies that pose a significant risk to the financial stability of the U.S. economy, arguing that because the liquidation authority includes the power to alter the priority of creditors, it violates the Constitution's Bankruptcy Clause, which guarantees uniform bankruptcy laws, as well as the non-delegation and due process doctrines.

 

The DC Circuit first considered whether the bank had standing to challenge the constitutionality of the CFPB, and, if so, whether the claim was ripe now or would only be ripe later when an enforcement action was filed against the bank.

 

The standing question focused on whether the bank "had suffered an injury in fact caused by the [CFPB] and redressable by the Court."  Because the Supreme Court has noted that "there is ordinarily little question" that a regulated entity has standing to challenge an allegedly illegal statute or rule, the DC Circuit had no difficulty concluding that the bank had standing to challenge the CFPB's constitutionality.

 

Turning to the question of when the bank could sue or "ripeness," the DC Circuit also had little difficulty concluding that, based Supreme Court precedent, the bank did not have to violate the law in order to challenge the law or, in this case, the authority of the regulating agency itself.

 

Because the parties had not briefed the merits of the constitutionality of the CFPB, the Court DC Circuit and remanded to the district court to consider the merits of that claim.

 

The DC Circuit also concluded, for the same reasons that the bank could challenge the constitutionality of the CFPB, it also had standing to challenge President Obama's recess appointment of the CFPB's director, and that the challenge was ripe. The district court's ruling on this issue was reversed and the case remanded for consideration of the merits in light of the Supreme Court's 2014 decision in NLRB v. Noel Canning.

 

The Court specifically instructed the district court to consider the "significance of Director Cordray's later Senate confirmation and his subsequent ratification of actions he had taken while serving under a recess appointment."

 

However, the DC Circuit rejected the bank's challenge to the Financial Stability Oversight Council.  The Court held that the bank lacked standing because it was not on the "too big to fail" list and, although its main competitor in Texas was, the doctrine of competitor standing, which allows in limited instances a plaintiff to challenge the Government's under-regulation of the plaintiff's competitor, did not apply because in the case at bar, the competitor was under a heavier, not lighter, regulatory burden as the result of the Dodd-Frank Act, and any harm to the plaintiff bank was "simply too attenuated and speculative to show the causation necessary to support standing."

 

Accordingly, the district court's judgment that the bank lacked standing to challenge the Financial Stability Oversight Council was affirmed.

 

The DC Circuit then turned to the State plaintiffs' challenge to the Dodd-Frank Act's "orderly liquidation authority," concluding that the States lacked standing and their claims were also not ripe because:  (a) the State plaintiffs would be affected only if a financial company in which they invested is liquidated or reorganized by the Government and then only if the Government treated them differently than other similarly situated creditors; and  (b) "[i]t is premature for a court to consider the legality of how the Government might wield the orderly liquidation authority in a potential future proceeding."   

 

 

 

 

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

 

 

CALIFORNIA   |   FLORIDA   |   ILLINOIS   |   INDIANA   |   NEW JERSEY   |   NEW YORK   |   OHIO   |   PENNSYLVANIA   |   TEXAS   |   WASHINGTON, D. C.

 

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:

 

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FYI: 8th Cir Rejects Application of "Juridical Link" Doctrine to Confer Standing, Holds SOL for MSMLA Claims is 3 Years

The U.S. Court of Appeals for the Eighth Circuit recently affirmed the dismissal of a class action by Missouri borrowers alleging that various assignees and purchasers of second mortgages charged or collected illegal fees in violation of Missouri Second Mortgage Loan Act (MSMLA), holding that plaintiff borrowers lacked standing to sue the defendants who did not service their loans. 

 

In so ruling, the Eighth Circuit refused to apply a state appellate court ruling made during the long history of this action, instead ruling that the MSMLA has a three-year statute of limitations, and that this three-year statute of limitations began to run when the subject origination fees were charged.

 

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

 

The borrowers, whose loans were secured by second mortgages on their homes, sued in state court. The case was twice removed to federal court and twice remanded to the state court, with the state court eventually granting summary judgment for the defendants on the basis that the 3-year statute of limitations had expired.

 

The borrowers appealed to the Missouri Court of Appeals, which reversed and remanded the case, holding that a 6-year statute of limitations applied. The borrowers then filed their sixth amended complaint, naming a national bank as a defendant for the first time. The bank removed the case to federal court pursuant to the federal Class Action Fairness Act and the district court denied the borrowers' motion to remand to state court.

 

The district court then granted the bank's motion to dismiss as to loans that it held directly or as trustee because the named class representatives lacked standing to sue. The borrowers appealed to the U.S. Court of Appeals for the Eighth Circuit.

 

On appeal, the Eighth Circuit first addressed the issue of standing, which federal courts must do before turning to the merits when the issue of standing is raised.  As you may recall, Article III of the U.S. Constitution limits the jurisdiction of federal courts to "cases and controversies." "A case or controversy requires a plaintiff to have standing. Standing requires a plaintiff: (1) to have suffered a concrete injury in fact, (2) to prove a causal connection between the injury and the defendant's allegedly unlawful conduct, and (3) to show the injury is capable of redressability through a favorable ruling from the courts."

 

The Eighth Circuit agreed with the district court that the plaintiff borrowers lacked standing to sue the bank because there was no causal connection between the alleged charging and collecting of improper fees and the bank, who never collected any such fees from the plaintiffs.

 

The Court rejected the borrowers' argument that the trial court's order certifying the class conferred standing because it is settled law that "[a] class certification order does not confer standing on a plaintiff who otherwise lacks it."

 

The Court also rejected the borrowers' argument that they had standing under the "juridical link" doctrine, which "allows a named plaintiff to bring a class action against parties that did not cause the named plaintiff's injury if the plaintiffs suffered identical injuries by parties related through a conspiracy or concerted scheme and suing all parties in one action would be expeditious." Under this doctrine, once a court certifies a class, standing is analyzed with reference to the class as a whole, not with reference to the individual named class representatives.

 

Although the issue was one of first impression in the Eighth Circuit, the Court agreed with other circuits that found, under similar circumstances, that the doctrine does not confer standing on the borrowers.

 

Finally, the Eighth Circuit rejected the borrowers argument that the federal Home Ownership Equity Protection Act ("HOEPA"), conferred standing on them because "the courts that have considered the issue have held that nothing in HOEPA purports to confer standing that is otherwise lacking."

 

Because the plaintiff borrowers lacked standing to sue the bank, who did not purchase and did not service their loans, the district court's dismissal of the complaint against the bank was affirmed.

 

In addition, the Eighth Circuit held the plaintiff borrowers' claims were time-barred.

 

Earlier in this prolonged litigation, the Missouri appellate court held that MSMLA claims are subject to a six-year statute of limitations.  Schwartz v. Bann-Cor Mortgage, 197 S.W.3d 168 (Mo. Ct. App. 2006).  The borrowers argued that the ruling by the Missouri appellate court earlier in the litigation should apply, because it "is the best pronouncement of Missouri law and its holding should be applied to this case," and under the law of the case doctrine.

 

However, the Eighth Circuit rejected the Missouri appellate court's ruling, referencing its prior rulings in Rashaw v. United Consumers Credit Union, 685 F.3d 739 (8th Cir. 2012), cert. denied, 133 S. Ct. 1250 (2013), Washington v. Countrywide Home Loans, Inc., 747 F.3d 955, 958 (8th Cir.), cert. denied, 135 S. Ct. 307 (2014), and Huffman v. Credit Union of Tex., 758 F.3d 963, 966 (8th Cir. 2014), in which the Eight Circuit repeatedly held that the three-year statute of limitations applied, after conducting a thorough analysis of both Missouri case law and legislative history.

 

The Eighth Circuit also rejected the borrowers' argument that the law of the case doctrine required application of the Missouri appellate court's ruling.  Under the law-of-the-case doctrine, "`a court should not reopen issues decided in earlier stages of the same litigation.'" In re Raynor, 617 F.3d 1065, 1068 (8th Cir. 2010).  However, "the doctrine does not apply if the court is convinced that [its prior decision] is clearly erroneous and would work a manifest injustice." Pepper v. United States, 131 S. Ct. 1229, 1250-51 (2011).  The Court held that the exception to the law of the case doctrine applied here,

 

The borrowers then argued that their causes of action did not accrue at the time of loan origination, but rather accrued when the assignees acquired or began collecting on the loans. Under Missouri law, a cause of action accrues "[w]hen the fact of damage becomes capable of ascertainment . . . even if the actual amount of damage is unascertainable." Bonney v. Envtl. Eng'g, Inc., 224 S.W.3d 109, 116 (Mo. Ct. App. 2007). "Damage is capable of ascertainment when it can be discovered or is made known, even if its extent remains unknown." D'Arcy & Assocs., Inc. v. K.P.M.G. Peat Marwick, L.L.P., 129 S.W.3d 25, 29 (Mo. Ct. App. 2004).

 

However, the Eighth Circuit held that the borrowers' causes of action accrued with the origination of their loans. Explaining its ruling, the Eighth Circuit noted that "the 'fact of damage' would have been 'capable of ascertainment' when the loans closed because the borrowers allege that the impermissible fees were wrapped into the principal amount of the loan," and "[t]he three-year statute of limitations thus began to run when the loans closed."

 

The Eighth Circuit also rejected the plaintiff borrowers' arguments that their claims "related back" to the original filing of this action within the limitations period.  The Court held that "[a]n evolving strategy, rather than a mistake in identity, caused the borrowers to add additional defendants."  This, the Court held, prevented application of the relation back doctrine.

 

Lastly, the Eighth Circuit rejected the borrowers' argument that HOEPA's allowance for derivative liability for assignees somehow extended the statute of limitations period on their state-law claims.

 

 

 

 

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

 

 

CALIFORNIA   |   FLORIDA   |   ILLINOIS   |   INDIANA   |   NEW JERSEY   |   NEW YORK   |   OHIO   |   PENNSYLVANIA   |   TEXAS   |   WASHINGTON, D. C.

 

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