Photo of Grant A. Premo

Grant Premo represents financial services institutions and other businesses across the country in a variety of commercial litigation and compliance matters. He has experience advising clients on lending, servicing and operations in the areas of student lending and residential and commercial mortgage lending, including helping develop best practices for telephone and text-message communications with consumers to comply with the Telephone Collection Practices Act (TCPA). Grant litigates matters involving state law tort and contract claims and claims of violations of federal and state laws, including the TCPA, Truth in Lending Act (TILA), Fair Debt Collection Practices Act (FDCPA), Fair Credit Reporting Act (FCRA), Real Estate Settlement Procedures Act (RESPA), Home Ownership and Equity Protection Act (HOEPA), the Servicemembers Civil Relief Act (SCRA), state unfair and deceptive trade practice statutes, government loan programs, and mortgage lending, servicing and securitization practices. Grant also assists financial services clients facing investigations and enforcement actions by an attorney general, the CFPB and other regulators.

CFPB Signals Continued Progress Toward Dodd-Frank 1071 Notice of Proposed RulemakingOn the heels of CFPB Acting Director Dave Uejio’s recently released statement to agency staff members, the Bureau again signaled that it is making progress toward issuing a Notice of Proposed Rulemaking (NPRM) enacting Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act). Specifically, in late February, the CFPB

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

CDC Issues Eviction Moratorium, but Will It Survive Legal Challenge?The Centers for Disease Control (CDC) recently issued a sweeping moratorium on most evictions through the end of 2020 as a means to stop the spread of COVID-19, which will go into effect on September 4, 2020. According to government estimates, the order will cover up to 40 million renters nationwide. This unprecedented exercise of

Credit Reporting During the COVID-19 Outbreak: CFPB Issues FAQs for CARES Act RequirementsThe CFPB recently issued its “Consumer Reporting FAQs Related to the CARES Act and COVID-19 Pandemic,” addressing 10 credit reporting issues. While the FAQs provide some much-needed clarity for furnishers of information and credit reporting agencies, the CFPB left some significant questions unanswered.

Below we breakdown highlights of the FAQs:

  • Several of the FAQs —

Lender Liability and False Claims Act Issues under the Paycheck Protection ProgramAmong the most significant aspects of the CARES Act is the $660 billion small business forgivable loan program known as the Paycheck Protection Program (PPP), and it was perhaps inevitable that the administration of the program would be followed by a wave of related litigation. Already, the PPP application process has generated lawsuits over the

Federal Law Preempts Connecticut’s Student Loan Servicer Licensing Law, According to Federal CourtSeveral states have recently ramped up their regulation of the student lending industry by passing laws requiring student loan servicers to be licensed in the state in order to operate there. Many of these state licensing laws are creating conflicts for servicers in an industry already dominated by federal law. Now a U.S. District Court

Misrepresentation Claims Not Preempted: Eleventh Circuit Rules Against Preemption in Student Loan CaseAs we’ve been tracking for over a year now, courts across the country have addressed the significant question of whether the federal laws governing federally owned or guaranteed student loans preempt state laws placing burdens on servicers of those loans. Last week, the Eleventh Circuit became the latest court to weigh in, holding in Lawson-Ross

Credit Reporting Requirements and COVID-19 – CFPB and FHA Weigh InThe CFPB’s April 1, 2020, statement regarding credit reporting for loans affected by COVID-19 announced a “flexible supervisory and enforcement approach during this pandemic.” In addition to guidance regarding furnishing obligations while consumers are impacted by COVID-19, the bureau specifically announced relaxed enforcement standards for companies struggling to respond to consumer credit disputes within the

Credit Reporting Requirements and COVID-19 – CFPB and FHA Weigh InWe’ve been tracking regulatory developments related to credit reporting for loans where borrowers have been affected by the coronavirus outbreak. On April 1, the CFPB issued a statement about credit reporting for loans affected by COVID-19. The statement announces the CFPB’s “flexible supervisory and enforcement approach during this pandemic” and seeks to reassure credit reporting

How Is the COVID-19 Pandemic Impacting the Student Lending Industry?Like the country and economy at large, the COVID-19 pandemic is significantly impacting secondary education and the student lending industry. In response to the pandemic, colleges across the country closed their campuses, sent students home, and turned to online learning platforms, creating uncertainty for current student borrowers. President Trump, Congress, and the U.S. Department of