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Andrew Narod is an experienced litigator who represents bank and non-bank financial services institutions and other types of businesses in class-action litigation, complex commercial litigation, and other high-profile litigation disputes nationwide. His clients entrust him to navigate some of their most sensitive litigation matters in some of the most difficult venues in the country.

CFPB States Intent to Scrutinize Auto Lender Repossession PracticesOn February 28, 2022, the CFPB released a Compliance Bulletin and policy guidance entitled “Mitigating Harm from Repossession of Automobiles.” In its bulletin, the CFPB sets forth the objective of reminding market participants of certain legal obligations under federal consumer protection laws in light of what it perceived to be “risky auto repossession

CFPB Warns of Serious Issues with Fair Lending Standards for AppraisersThe Consumer Financial Protection Bureau (“CFPB”) released a blog post on February 4 warning of the possibility of discrimination in the appraisal process. The CFPB explained that, although appraisal discrimination based on racial inequalities has been outlawed for more than 50 years, they are still seeing reports of biased appraisers who “base their value judgments

FCC Targets “Ringless Voicemails” for Robocalling EnforcementThe Federal Communications Commission (FCC) is considering opening another front in robocalling enforcement by declaring “ringless voicemails” subject to consumer consent and other requirements under the Telephone Consumer Protection Act (TCPA). Ringless voicemails deliver messages directly to wireless users’ voicemail boxes without ringing their devices. Proponents of the technology have long argued that such messages

CFPB Fall Supervisory Highlights Shed Light on Agency Priorities – Fair LendingAs 2021 came to an end, the Consumer Financial Protection Bureau (CFPB) released its 2021 Fall Supervisory Highlights, which cover the CFPB’s findings of examinations completed on the first half of the year. Though the CFPB’s Fair Lending Supervision Program reviews compliance with the Equal Credit Opportunity Act (ECOA) and its implementing regulation, Regulation B,

In a development that provides some measure of relief to businesses operating in West Virginia, particularly within the financial services industry, Gov. Jim Justice signed into law on March 29, 2021, amendments to the West Virginia Consumer Credit and Protection Act (WVCCPA). These amendments appear to provide clarity on certain attorneys’ fees provisions in the

In a landmark decision released this morning, the U.S. Supreme Court finally answered the question that has been at the heart of Telephone Consumer Protection Act (TCPA) litigation for decades – what constitutes an autodialer? – and the decision is a huge win for TCPA defendants. In Facebook v. Duguid, the Supreme Court unanimously

Illinois Caps Consumer Loans at 36% Rate, Limiting Consumers’ Access to CreditLast week, Illinois enacted the “Predatory Loan Prevention Act” (SB 1792), which would place a 36% rate cap on nearly all non-bank consumer loans. This act will essentially outlaw small-dollar loans in Illinois and may make ancillary products on auto loans, such as GAP insurance, unavailable for a large number of consumers. The act

Federal Reserve Acts to Bolster Auto Finance, Credit Card, Student Lending IndustriesIn an action somewhat lost amidst the unprecedented $2 trillion Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Federal Reserve’s Board of Governors announced a series of five “extensive new measures” to provide liquidity for certain sectors of the nation’s economy. One of those liquidity facilities, the reintroduced Term Asset-Backed Securities Loan Facility

Department of Defense Withdraws Troublesome Military Lending Act GuidanceIn a significant victory for servicemembers and their families, who will again have access to products designed to protect them in the event of a total vehicle loss, the Department of Defense has revised its guidance that previously prevented auto lenders from offering service members Guaranteed Asset Protection (GAP) waivers in connection with a vehicle

Maryland Court of Appeals Bars Confessed Judgment Clauses in Consumer ContractsA recent decision from the Maryland Court of Appeals provided somewhat surprising new guidance on the permissibility of confessed judgment clauses in consumer contracts. In Goshen Run Homeowners Association, Inc. v. Cisneros, the Court concluded that Maryland’s Consumer Protection Act (the “Maryland CPA”) prohibits all confessed judgment clauses in all consumer contracts.

In the