Editor's note: This article is authored by iA Legal Advisory Board members Aryeh D. Derman and Joann Needleman previously appeared as a Clark Hill News alert and is republished here with permission. Clark Hill Summer Associate Pawan Jain contributed to this article. This content—and all insideARM articles—are protected by copyright. All rights are reserved. The views and opinions expressed in the article represent the view of the author(s) and not necessarily the official view of Clark Hill PLC. Nothing in this article constitutes professional legal advice nor is intended to be a substitute for professional legal advice.

On July 11, the Consumer Financial Protection Bureau (“CFPB”) held a hearing on issues surrounding medical debt and specifically, payment products. Not surprisingly, the invited experts and special guests taking part in the discussion predictably targeted some key themes that are of recent interest to the Bureau: trendy exploitative practices targeting vulnerable individuals, the inadequate protection of consumers in a predatory marketplace, and the urgent need for regulatory reform to address and alleviate these systemic problems. While the panel was comprised of four accomplished consumer rights advocates, representatives from the healthcare and financial services sectors were noticeably absent and did not have an opportunity to confirm or rebut any of the volatile claims made. In this article, we summarize the hearing and point out the need for a nuanced regulatory approach that considers the complexities faced by healthcare providers, emphasizes consumer responsibility, and acknowledges the importance of proper risk assessments pertaining to the payment products discussed.

Exploitation of Vulnerable Consumers

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