2016 LAW – CREDITOR DOCUMENTATION

AN ACT CONCERNING CONSUMER COLLECTION AGENCIES AND DEBT COLLECTION ACTIONS.

Sec. 6. (NEW) (Effective October 1, 2016) In any cause of action initiated by a creditor, as defined in section 36a-645 of the general statutes, or by a consumer collection agency, as defined in section 36a-800, as amended by this act, for a liability on debt owed by a consumer debtor, as defined in section 36a-645 of the general statutes, the creditor or consumer collection agency shall attach the following materials to the complaint:

(1) A copy of the contract or other documentation evidencing the original debt and containing a signature of the consumer debtor or, if the debt is credit card debt and no such signed documentation exists, copies of the documentation generated when the credit card was used; and

(2) A copy of the assignment or other documentation (A) establishing that the plaintiff creditor is the owner of the debt, (B) containing the original account number and name associated with the debt, and, (C) if the debt has been assigned more than once, a copy of each assignment or other documentation that establishes an unbroken chain of ownership of the debt by the plaintiff creditor.

 

RULE 1 CAN BE SUMMARIZED AS FOLLOWS

THE FOLLOWING DOCUMENTATION NEEDS TO BE ATTACHED TO THE COMPLAINT

A.  IF NOT A CREDIT CARD DEBT –  A copy of the contract or other documentation evidencing the original debt and containing a signature of the consumer debtor

The important part of this rule is the requirement that the creditor have documentation with the consumer debtor’s signature.   Note that this is consumer debt, not commercial debt.   Also, a court should strike the complaint if there is no appropriate signature.

B.  IF CREDIT CARD DEBT – Either

1.  documentation with a signature   OR

2.   copies of the documentation generated when the credit card was used.    This should require credit card statements showing use of the card, with charges.     It should be insufficient to provide statements merely showing the accrual of interest and late fees.

RULE 2 APPLIES TO DEBT BUYERS – IT REQUIRES THREE POSSIBLE

ITEMS PROVING A PROPER ASSIGNMENT  OF THE DEBT (PROVES THAT

THIS CREDITOR HAS OWNERSHIP OF DEBT)

A.  PROOF THAT THE PLAINTIFF ACTUALLY OWNS THE DEBT – TYPICALLY THIS IS DONE BY AN AFFIDAVIT BY THE ORIGINAL CREDITOR, OR COPY OF DOCUMENTS SHOWING ASSIGNMENT

B.  DOCUMENTATION SHOWS ORIGINAL ACCOUNT NUMBER AND NAME   (THIS ALLOWS A DEFENDANT TO VERIFY THE ORIGINAL ACCOUNT INFORMATION)

C.  IF DEBT IS ASSIGNED MORE THAN ONCE, PROOF OF EACH TRANSFER, FROM CREDIT GRANTOR TO CURRENT PLAINTIFF (IN SOME CASES, THE DEBT HAS BEEN TRANSFERRED MULTIPLE TIMES, AND THE FINAL OWNER CANNOT PROVE THAT EACH TRANSFER WAS LEGAL)

Attorney Robert M. Singer

Law Offices of Robert M. Singer, LLC

2572 Whitney Avenue

Hamden, CT  06518

203-248-8278

rsingerct@yahoo.com

 

PAYDAY LOANS IN CONNECTICUT – NEW LAW – 2016

The following is from the Office of Legislative Research

Regarding the changes to the small loan statutes, the bill, among other things, expands the scope of activities that require licensure and simplifies the definition of a “small loan,” which under the bill is any monetary loan or extension of credit, or the purchase of, or an advance of money on, a borrower’s future income where the amount or value is $15,000 or less and the Annual Percentage Rate (APR) is greater than 12%. It also converts the existing interest rate structure to an APR capped at the maximum 36% allowed under the federal Military Lending Act. It requires small loan licensure to be done through the Nationwide Mortgage Licensing System and Registry (NMLS or “the system”) and changes the license application fee structure and the length of time a license remains valid. It establishes permitted and prohibited licensee practices and loan provisions.

 

The most relevant provisions are the following, in Connecticut General Statutes 36a-555

  1.  It is a “small loan” under $15,000
  2.  Based on a “borrowers future income”
  3. The Annual percentage rate is capped at 36%

 

 

Further Connecticut General Statutes CGS 36a-566provides in part that

pursuant to section 36a-565, as amended by this act, no person shall, by any method, including, but not limited to, mail, telephone, Internet or other electronic means, unless exempt pursuant to section 36a-557, as amended by this act:

(1) Make a small loan to a Connecticut borrower;

 

Important things to note, this applies to

  1.  internet loans
  2. small loans to consumer borrowers and
  3.  appears to make a small loan unenforceable if there is no license by the lender

Attorney Robert M. Singer

Law Offices of Robert M. Singer, LLC

2572 Whitney Avenue

Hamden, CT  06518

203-248-8278

rsingerct@yahoo.com

 

 

DEBIT CARD OVERDRAFT SERVICE

The Service can be summarized as follows

  1.  You are using your ATM card

2.  You don’t have enough money in your checking account to cover the transaction

3.  The Service allows you to continue to use the ATM card.

 

I looked at the Consumer Account Agreement with Wells Fargo.   As is typical with these Agreements, if you do not make a deposit by a cut-off date, you are charge a fee.

Watch out with this Service.  It is very easy to use your ATM several times, without even realizing that you have no funds in your account.   The overdraft charges can easily add up to $100 or $200, or more.

Since this is an optional service, it is best to “opt out” of the service.

Attorney Robert M. Singer

Law Offices of Robert M. Singer, LLC

2572 Whitney Avenue

Hamden, CT  06518

203-248-8278

rsingerct@yahoo.com

 

 

 

LEASING OR LOANS – FOR VEHICLES

 

For most people, leasing is a simple option, but a bad move.

 

One of the biggest problems with leasing a vehicle is that the lease may

limit the amount of driving which you perform, on a vehicle, without a

surcharge.  Generally, the lease will allow you to drive 10,000 to 15,000

miles per year, without the surcharge.  The typical lease term is 3 to 4

years.  If you exceed the leases permitted mileage, you will be subject to

the surcharge, which can add up to thousands of dollars at the end of a

lease term.  The surcharge per mile varies depending on the vehicle, but I

have seen typical amount of approximately 20 cents per mile.  Assuming,

you are 60,000 miles over the lease mileage, this leaves a balance due of

$12,000.

 

A lease only makes sense for someone who will clearly be driving the car

below the mileage limit set in the lease contract.  In addition, if you intend

to lease, you will want an option to buy the car, at the end of the lease

term, if you like the car.  This way, you can get rid of the vehicle, if it does

not suit your needs, or buy the car if it suit your longer term needs (lease

with an option to buy).

 

For most people, it is simply wiser to buy a vehicle, tha55555555n lease.  A vehicle

can last far beyond the lease term.  Typically, it takes 5 years, under

normal situations, to pay off a motor vehicle loan.  If you are continuously

leasing cars, it is like continuously buying a new car, every 2 to 4 years,

and never owning anything.  In addition, if you exceed the limited mileage

on a lease contract, you get a surcharge.

Attorney Robert M. Singer

Law Offices of Robert M. Singer, LLC

2572 Whitney Avenue

Hamden, CT  06518

203-248-8278

rsingerct@yahoo.com

VEHICLE OIL CHANGES – TOO OFTEN CAN BE A WASTE OF MONEY

There are many quick oil changes places.    The establishments make money by changing oil.   Watch out.

Traditionally, it was recommended that oil be changed in a vehicle every 3,000 miles.  The rules have changed.

I have gone for oil changes at a major oil change center.  I have been told that I can choose to change the oil every 3,000 miles for synthetic oil.  I told the attendant that I will wait the 5,000 miles for the oil change;  the oil change business has changed with the new oils.  Frequent changes means more money for these business, so they are often selling a more frequent service which you don’t need.

Remember that an oil change includes changing the filter.  One reason not to wait more than 3 months for an oil change is that the filter may not last longer than 3 months.

I have a car with an oil monitor, which is supposed to have a light come on when the oil needs to be changed.  I don’t trust the monitor.  Even if the oil is still “good,” the filter may be too old and need changing.  Furthermore, motor vehicles are driven under different conditions, city driving as compared to highway driving, or short trips as compared to long trips.  My concern is that different driving conditions can affect oil quality.  An engine is simply too expensive to repair, if the monitor doesn’t work effectively.

For a website discussing oil change intervals, go to

http://www.calrecycle.ca.gov/UsedOil/OilChange/

I have a 2010 Chevrolet Malibu and the site indicates that the change interval is every 7,500 miles.  I use synthetic oil and still change ever 5,000 miles.   I am being a bit conservative, but the car is often driven short distances.

Attorney Robert M. Singer

Law Offices of Robert M. Singer, LLC

2572 Whitney Avenue

Hamden, CT  06518

203-248-8278

rsingerct@yahoo.com