In “CFPB Enters Consent Order with Consumer Lender over Debt Collection and Credit Reporting Practices,” Mr. Yarborough and Mr. Rosenkoetter discuss a consent order with a holding company and its affiliated operating entities engaged in consumer lending, issued by the Bureau of Consumer Financial Protection.

They write, “The lenders were collecting their own debt, and their principal purpose is consumer lending and not debt collection, thus their collection activities were not governed by the Fair Debt Collection Practices Act (“FDCPA”). Instead, the Bureau used its authority under the Dodd-Frank Wall Street Reform and Consumer Protection Act to find a that number of the lenders’ collection activities were ‘unfair, deceptive, or abusive acts or practices’ (UDAAP).”