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Jeffrey P. Naimon quoted in Law360 article, “CFPB settlement would reduce $3.8M sanction to just $22K”
Law360Jeffrey P. Naimon
Jeffrey P. Naimon was quoted on July 9, 2020 in a Law360 article, “CFPB settlement would reduce $3.8M sanction to just $22K,” which discussed a pending settlement involving the Consumer Financial Protection Bureau and a student loan debt-relief company that would significantly reduce a proposed $3.8 million sanction to $22,000.
Naimon noted, “The regulator wants to set a high bar with its official penalty amounts, but that it's willing to exhibit leniency with small companies who are unable to pay rather than force lengthy and unproductive bankruptcy proceedings. If the company that's the target of the settlement is basically three guys in a garage, the CFPB enforcement staff doesn't want to establish a monetary penalty based on what the company can actually pay. Enforcement is intended to send a message to others in the market, and setting a higher penalty based on what staff believes is appropriate — even if they can't collect the entire amount — sends that message."
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