Overly optimistic assumptions that can create false impressions for borrowers can easily rise to the level of an unfair and deceptive act or practice. As seen in an administrative action recently filed against an online payday lender, disclosures made to consumers need to reflect the terms of the loan in both the best and worst case scenarios. The action, filed by the Consumer Financial Protection Bureau, alleges that Integrity Advance LLC and its former chief executive officer engaged in unfair and deceptive acts by misrepresenting the cost of loans. The lender notified borrowers of the cost of their loans using the assumption that the short term loans would be repaid on the date the first installment came due.
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Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide. Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.
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