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  • Posts by Sanjay Ibrahim
    Partner

    Sanjay Ibrahim serves as the Managing Partner of Parker Ibrahim & Berg LLP, and has served in that capacity since 2011. He chairs the Firm’s Executive Committee and has led the strategic direction of the Firm in its growth from a ...

On October 17, 2018, the American Bar Association’s Standing Committee on Ethics and Professional Responsibility (the “Committee”) issued Formal Opinion 483 (the “Opinion”) entitled Lawyers’ Obligations After an Electronic Data Breach of Cyberattack.

On June 6, 2018, the Consumer Financial Protection (CFBP) disbanded its Consumer Advisory Board (CAB) as well as two other advisory councils, the Community Bank Advisory Council and the Credit Union Advisory Council. The 60 plus members of the three committees were told during a conference call that they were being disbanded and restructured with new membership.

On Wednesday, April 18, 2018, the Senate passed a measure to repeal the Consumer Financial Protection Bureau’s (“CFPB's”) 2013 guidance prohibiting discrimination in auto lending (the “2013 Guidance”).  In 2013, the CFPB issued a bulletin regarding compliance with the fair lending requirements of the Equal Credit Opportunity Act (“ECOA”) and its implementing regulation, Regulation B, for indirect auto lenders that permit dealers to increase consumer interest rates and that compensate dealers with a share of the increased interest revenues. The 2013 Guidance noted that that some indirect auto lenders had policies that permitted auto dealers to mark-up rates and that compensated dealers for those mark-ups.  As a result of the policy incentives and the discretion permitted in the mark-ups, the CFPB concluded that there was a significant risk of pricing disparities on the basis of race, national origin, and other prohibited bases, in violation of ECOA.

The Seventh Circuit Court of Appeals has ruled that the Truth in Lending Act (“TILA”) requires that mortgage servicers must credit consumer accounts with online mortgage payments on the date the consumer authorizes payment, not the date when the servicer receives the funds from the consumer’s bank.

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