Carly Souther is General Counsel and COO at iTrain OnDemand (iTod), where she provides guidance on legal and compliance issues for clients in the U.S. financial industry. She formerly served as Chief of Regulation at ECigIntelligence and was the Assistant General Counsel at Florida's Agency for Health Care Administration.
Carly has published on a wide range of issues in both legal and medical journals, including the Georgetown Journal on Poverty Law & Policy and the University of Iowa's Transnational Law & Contemporary Problems. She is a member of the Florida Bar, and holds an M.A. from the Universitat Autònoma de Barcelona; a J.D. from the Florida State University College of Law; and a B.A. from Mercer University.
In its $28.5 million settlement with Navy Federal Credit Union (NFCU), the Consumer Financial Protection Bureau (CFPB) stated that NFCU's collection letters contained material misrepresentations – or unfair or deceptive abusive acts or practices – that were likely to mislead consumers; how did NFCU's templates violate UDAAP?
In May 2019, the CFPB issued a Notice of Proposed Rulemaking (NPRM) for the Fair Debt Collection Practices Act (FDCPA); how has this rule updated the antiquated FDCPA? the NPRM will likely have a dramatic impact on collection practices for debt collectors.
Did the Supreme Court’s decision in Henson v. Santander Consumer USA, Inc. obviate the necessity for first party creditors to comply with the CFPB’s debt collection rules?
For years, the Consumer Financial Protection Bureau (CFPB) has promised to prioritize rulemaking based on consumer complaints. The proposed rule was released in May 2019, but what effect, if any, does the proposed rule have on first-party creditors? What other regulatory concerns related to debt collection should my bank be aware of?
How are the CFPB and FTC protecting military consumers from first-party debt collection?
If my bank qualifies for, and opts into, the Community Bank Leverage Ratio (CBLR) Framework for our March 31, 2020, Call Report, can we opt OUT of the Framework at a later date?
Have the October 2019 proposed changes for the Community Bank Leverage Ratio (CBLR) Framework been finalized?
Will opting-in to the Community Bank Leverage Ratio (CBLR) Framework change how my bank's assessment rate is calculated?
Has COVID-19 had any impact on the call report?
What is the Grace Period for the Community Bank Leverage Ratio (CBLR) Framework?