June 13, 2022
Good Morning,
We will soon enter the tenth year of our
Borrow Smart Compliance program. If you measure the success of
this program by
the standard of CFPB examinations, this program has been quite a
success.
When we began, we engaged
Jeremy Rosenblum and other attorneys with Ballard Spahr to
craft and maintain our CFPB policy manual. Ballard is a
nationally ranked law firm in consumer finance, and the work
Jeremy and Ballard did for us turned out to be right on target!
However, nothing lasts forever, and Jeremy recently moved to
another firm. The new firm is the top fifty national law
firm of Troutman
Pepper. Jeremy and
a group of other consumer finance attorneys all made the move.
In fact, almost all of the attorneys we worked with at Ballard
made the move with Jeremy.
We also made the move with Jeremy. While
we believe Ballard is an excellent firm, Troutman Pepper is
larger and has a more significant presence. Nothing will change
with the move. It will be the same people but with a different
email address and telephone number :-).
Over the years, we have had several
updates to the policy manual and training courses due to rule
changes by the CFPB and other federal agencies. We don't expect
the updates to stop now. In fact, we will soon begin working on
a significant update to our Information Security policy that is
a part of the Gramm-Leach-Bliley Act. The new rule is an update
to the
Safeguards Rule. The rule addresses privacy issues -- both
IT security and traditional security.
This new rule is quite complex and has
many moving parts -- including healthy fines for non-compliance.
And it is enforced by both the FTC and the CFPB. We will have
more updates on this topic soon.
If you have any questions or comments,
please email or call us.
Thanks.
- Max
Questions or comments?
Email us at
info@borrowsmartcompliance.com
Direct Tel: 205-733-9926
