Bureau Guidance on MSAs Goes Over Like a Lead Balloon
October 19, 2015
A cross-section of industry representatives and analysts were not very impressed with the long-sought guidance on marketing services agreements that the CFPB put out recently. Michael Barone, a director of legal and regulatory compliance at Lenders Compliance Group, a consulting firm in Long Beach, NY, said the guidance – which he characterized as very short and informal – “was an effort to get something out very quickly,” in response to all the congressional criticism that CFPB Director Richard Cordray received at the hands of critics on Capitol Hill. “It really does not have a lot of teeth at all,” he said of the bulletin. Further, the guidance doesn’t “tell us anything more than where we were an hour before this guidance came ...