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Adam Levitin
Recent Activity
I used my phone to remotely deposit a check today at Bank of America. Before I was able to proceed with the transaction, however, Bank of America required me to agree to new terms and conditions for mobile deposits. The... Continue reading
Posted Mar 13, 2021 at Credit Slips
The Biden administration could substantially reduce the number of "credit invisible" and "thin file" consumers without legislation, simply through a determined use of federal contract regarding multi-family mortgages and wireless spectrum licenses. By requiring credit reporting as a condition of... Continue reading
Posted Feb 26, 2021 at Credit Slips
Some Texas consumers who didn't lose power are now finding themselves socked with massive electric bills, as high as $17,000. The reason? They were paying variable kW/h pricing for their electricity at wholesale rates, without any sort of price collar.... Continue reading
Posted Feb 21, 2021 at Credit Slips
The latest development in the NRA bankruptcy is the NRA's motion to retain Kirkland & Ellis as special counsel. The retention seems to be for appellate issues, and the partner submitting the retention affidavit is an appellate specialist, not a... Continue reading
Posted Feb 18, 2021 at Credit Slips
The NRA's Gone to Texas bankruptcy just keeps getting wilder and wilder. First an NRA board member files a motion for an examiner. Then the NRA's largest creditor files a motion for the case to be dismissed as a bad... Continue reading
Posted Feb 17, 2021 at Credit Slips
In my previous blog post on the NRA bankruptcy, I was focused on the bankruptcy implications of the incredible examiner motion filed by an NRA board member against the NRA. But as I think about it more, it's also got... Continue reading
Posted Feb 9, 2021 at Credit Slips
As I predicted, things were not going to go so smoothly for the National Rifle Association in bankruptcy. Today, the Hon. Phillip Journey, a Kansas state judge who was recently elected to the NRA's board of directors, filed an examiner... Continue reading
Posted Feb 8, 2021 at Credit Slips
Once in a while you see an empirical paper that makes you say "wow." That's my first reaction to an NBER paper out from some economists and a sociologist at Duke and UNC. The paper, entitled "Housing Precarity & the... Continue reading
Posted Feb 3, 2021 at Credit Slips
The National Rifle Association filed for bankruptcy in the Northern District of Texas (Dallas). The NRA's press release says that the purpose of the bankruptcy is to enable the NRA to change from being a New York corporation to a... Continue reading
Posted Jan 15, 2021 at Credit Slips
I have an op-ed about the Consumer Bankruptcy Reform Act running on CNBC's site. Given that both collection moratoria and benefit extensions keep getting dribbled out in one to three month bites, we will definitely see an expiration of both... Continue reading
Posted Jan 11, 2021 at Credit Slips
Remember Mick Mulvaney? He was a Tea Party Congressman who became head of OMB for Trump and was then named acting CFPB Director and ultimately acting Chief of Staff for Trump before being appointed special envoy to Northern Ireland. Well... Continue reading
Posted Jan 7, 2021 at Credit Slips
The CFPB has been chugging out enforcement actions and settlements at a fairly fast clip the last several months. Part of that might be businesses deciding to settle because they think they're going to get a better deal with Director... Continue reading
Posted Jan 5, 2021 at Credit Slips
I filed an amicus brief today in Becerra v. Brooks, the challenge brought by the California, Illinois, and New York attorneys general against the OCC's "Madden-fix" rule. Consider it a stocking stuffer for the Acting Comptroller, Brian Brooks, and a... Continue reading
Posted Dec 23, 2020 at Credit Slips
It's time to say it loud and clear: the OCC is a problem agency. Here's a list of only some of the issues from the past year: the fair access rule, toleration of rent-a-banks, the valid-when-made rule, the true lender... Continue reading
Posted Dec 18, 2020 at Credit Slips
I submitted comments to the OCC about its proposed rulemaking regarding Fair Access to Financial Services. I previously blogged on the topic here and here. There are a LOT of problems in this poorly thought-through rulemaking, starting with whether there... Continue reading
Posted Dec 18, 2020 at Credit Slips
Public provision—whether public options or public monopoly—has become all the rage in some progressive circles. I’d like to claim early mover status in this regard—back in 2009 I wrote a piece calling for public provision in payments, and in 2013... Continue reading
Posted Dec 10, 2020 at Credit Slips
Today Senators Elizabeth Warren (D-MA), Dick Durbin (D-IL), and Sheldon Whitehouse (D-RI) and Representatives Jerrold Nadler (D-NY) and David Cicilline (D-RI) introduced the Consumer Bankruptcy Reform Act of 2020. This is the first major consumer bankruptcy reform legislation to be... Continue reading
Posted Dec 9, 2020 at Credit Slips
I'm usually fussing about bank regulation issues here on the Slips, but I do try to make time for my first love, business bankruptcy. Ted Janger and I have a short piece about restructuring support agreements out in the Yale... Continue reading
Posted Dec 6, 2020 at Credit Slips
It's not every day that I write a letter in opposition to the issuance of a bank charter. But that's what I just did. Here is my comment letter to the Office of the Comptroller of the Currency in opposition... Continue reading
Posted Dec 6, 2020 at Credit Slips
Jonathan Lipson and Gerald Posner have an important op-ed about the Purdue bankruptcy in the NYT and how the DOJ settlement with Purdue is likely to benefit the Sacklers. What's going on in Purdue is troubling, but not just for... Continue reading
Posted Dec 6, 2020 at Credit Slips
Those wascally wabbits at OCC are back at it again in the waning light of the Trumpshchina. The OCC has proposed a rule on "Fair Access to Financial Services." The gist of the rule is that banks cannot deny service... Continue reading
Posted Nov 20, 2020 at Credit Slips
The revelations about Donald Trump's taxes might hold in them an explanation for why he didn't divest from his businesses when he became President, despite the obvious political problems that was going to create: he couldn't afford divesting. Trump seems... Continue reading
Posted Sep 28, 2020 at Credit Slips
I am testifying later today (virtually) before the House Small Business Committee on "Transparency in Small Business Lending." My written testimony is here. Here's the background: consumer credit is governed by an extensive regulatory regime, starting with disclosure regulation, but... Continue reading
Posted Sep 9, 2020 at Credit Slips
Just when you think it can't get more ridiculous... The Office of Comptroller of the Currency, which hasn't taken racially discriminatory lending seriously, is concerned about banks' discriminatory refusal to serve the oil and gas industry. In fact, the OCC... Continue reading
Posted Aug 3, 2020 at Credit Slips
I have a new white paper out from the Roosevelt Institute's Great Democracy Initiative. The paper, which is co-authored with Lindsay Owens and Ganesh Sitaraman, proposes a standing emergency economic stabilization authority to provide an off-the-shelf immediately available response to... Continue reading
Posted Jun 30, 2020 at Credit Slips