The New York Department of Financial Services (DFS) has amended several provisions of its Third-Party Debt Collector and Debt Buyer Regulations and issued additional guidance in the form of new frequently asked questions...more
The Federal Reserve Bank of Cleveland recently issued a special report on the results of online focus groups it conducted with the Federal Reserve Board “to better understand small businesses’ perceptions of online...more
9/4/2015
/ Borrowers ,
Consumer Lenders ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Security ,
Federal Reserve ,
Financial Institutions ,
Loans ,
Online Marketplace Lending ,
Popular ,
Privacy Concerns ,
Request For Information ,
Small Business
The U.S. Department of the Treasury has extended the deadline for submitting comments in response to its request for information (RFI) regarding online marketplace lending. Initially set to close on August 31, 2015, the...more
The Department of Defense (DoD) dramatically expanded the scope of the Military Lending Act (MLA) on July 22, 2015, publishing its Final Rule amending the MLA’s implementing regulation. MLA coverage was previously limited to...more
7/28/2015
/ Automotive Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Unions ,
Department of Defense (DOD) ,
Financial Services Authority ,
Higher Education Act ,
Lenders ,
Military Lending Act ,
Military Service Members ,
Payday Loans ,
Regulation Z ,
Title IV
To resolve charges by the Consumer Federal Protection Bureau (CFPB) and the Department of Justice (DOJ) that it engaged in unlawful discrimination in violation of the Equal Credit Opportunity Act (ECOA), American Honda...more
7/17/2015
/ Automotive Industry ,
Automotive Loans ,
Borrowers ,
Compensation Agreements ,
Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Department of Justice (DOJ) ,
Discrimination ,
Disparate Impact ,
ECOA ,
Fair Housing Act (FHA) ,
Fair Lending ,
Financial Institutions ,
Honda ,
Interest Rates ,
Lenders ,
Race Discrimination ,
SCOTUS ,
Texas Dept of Housing v Inclusive Communities
The Federal Trade Commission (FTC) and the Florida Attorney General (AG) have jointly filed a complaint in a Florida federal court against several companies and their individual owners alleging that the defendants engaged in...more
7/3/2015
/ Computer Fraud and Abuse Act (CFAA) ,
Consumer Lenders ,
Debt-Relief Industry ,
Elder Abuse ,
Enforcement Actions ,
FDUTPA ,
Federal Trade Commission (FTC) ,
Financial Abuse ,
Financial Institutions ,
FTC Act ,
Nonbank Firms ,
Telemarketing
The Consumer Financial Protection Bureau has issued a final rule allowing it to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.” Relatedly, it adopted simultaneously a...more
The CFPB issued a final rule on June 10, 2015 allowing it to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.” Relatedly, it adopted simultaneously a separate rule...more
The U.S. Department of Education has issued proposed revisions to its Title IV Higher Education Act (HEA) cash management rules that include significant new restrictions on financial products used to disburse credit balance...more
The Federal Trade Commission—and numerous other federal, state, and local law enforcement agencies in the United States and Canada—recently announced that an enforcement initiative dubbed “Operation Ruse Control” has resulted...more
“Waiting for the CFPB’s arbitration study” isn’t the title of a new play but it does describe the study’s status as we enter the final hours of 2014.
Since the CFPB sent letters to payday lenders in August 2014...more
The consumer financial services attorney (the petitioner) who sued the New York State Department of Financial Services (DFS) and its superintendent, Benjamin Lawsky, to obtain access to DFS’s database of alleged illegal...more
In a clash of competing sovereigns’ interests, the Second Circuit recently upheld, for now, the authority of the New York Department of Financial Services (DFS) to regulate online payday loans made by Indian tribal lenders to...more
The U.S. Department of Justice (DOJ) recently settled a fair lending lawsuit against Texas Champion Bank. This means that, once again, a DOJ attempt to use disparate impact evidence to establish that a lender engaged in a...more