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Wednesday, December 20, 2017

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Cary Flitter

The existing validation notice at 1692g is not required to be provided verbatim. This, in turn, has spawned a tremendous amount of litigation over the adequacy, or overshadowing, of the notice. Individual cases, class cases by the dozen --over whether the disclosure of rights has been effectively conveyed or not. More regulation of the notice, specifically revamping it but requiring the specific disclosure would probably short-circuit much litigation against the industry. In this particular instance, less regulation here will yield more litigation.

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