Last month, we reported several laws scheduled to take effect this year. The first was the Commercial Financing Disclosure Law in Missouri. We have previously summarized this statute for commercial finance brokers who engage...more
The Fifth Circuit Court of Appeals has granted a stay in the case challenging the Consumer Financial Protection Bureau’s (CFPB) Small Business Lending Rule, also known as Dodd-Frank Section 1071. This rule, stemming from the...more
On January 10, 2025, the Consumer Financial Protection Bureau (CFPB) revived its policy statements on No-Action Letters (NALs) and Compliance Assistance Sandbox (CAS) Approvals. These unexpected changes come just days before...more
1/17/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
ECOA ,
EFTA ,
Enforcement Actions ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
No-Action Letters ,
Policy Statement ,
Regulatory Agenda ,
Regulatory Reform ,
Regulatory Requirements ,
Sandbox ,
Truth in Lending Act (TILA)
On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) published its highly anticipated notice of proposed rulemaking (NPRM) that would regulate data brokers and the sale of Americans’ personal and financial...more
12/6/2024
/ Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Credit History ,
Credit Reports ,
Data Brokers ,
Data Collection ,
Data Management ,
Data Sellers ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Proposed Rules ,
SBREFA
On November 13, the Consumer Financial Protection Bureau (CFPB) released a report on matched-pair testing in small business lending, highlighting potential racial discrimination. The study reveals that Black small business...more
11/27/2024
/ Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Dodd-Frank ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Financing ,
Popular ,
Race Discrimination ,
Small Business ,
Small Business Loans
In a move that has been a long time in the making, the Consumer Financial Protection Bureau (CFPB) has finalized its comprehensive open banking rule. The rule implements Section 1033 of the Dodd-Frank Act and grants consumers...more
Missouri is now part of the growing list of states who have introduced commercial finance disclosure requirements. Additionally, the statute – Section 427.300 of Missouri Senate Bill 1359 – contains substantial requirements,...more
On February 12, 2024, the Federal Financial Institutions Examination Council (FFIEC) issued a statement of principles that relate to valuation discrimination and bias for its member entities to consider in preparation for...more
2/21/2024
/ Bias ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Discrimination ,
Examination Procedures ,
FDIC ,
FFIEC ,
FHFA ,
Financial Institutions ,
Financial Services Industry ,
Mortgages ,
NCUA ,
OCC ,
Policies and Procedures ,
Valuation
One of the primary challenges with working in U.S. financial services is keeping up with the ever-changing federal and state regulatory landscape. Juggling the day-to-day fire drills while staying atop of regulatory changes...more
1/4/2024
/ Annual Percentage Rate (APR) ,
Anti-Discrimination Policies ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
Late Fees ,
Loans ,
Regulatory Agenda ,
Small Business
On August 30, 2023, the California Court of Appeals addressed whether the Rosenthal Fair Debt Collection Practices Act (Rosenthal FDCPA) protects a non-party to an agreement to pay for electricity produced by a solar energy...more
The Consumer Financial Protection Bureau (CFPB) has been at the forefront of discussions surrounding the evolving role of data brokers in today’s digital economy. In particular, Director Rohit Chopra recently announced that...more
Over the last several weeks, there have been two significant developments involving Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. First, on June 28, 2023, the Consumer Financial Protection...more
The Consumer Financial Protection Bureau (CFPB) recently released its Spring 2023 rulemaking agenda, signaling an expansion of its supervisory authority over the payments market. Of particular interest is the introduction of...more
6/30/2023
/ Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Dodd-Frank ,
Fees ,
Financial Services Industry ,
Insufficient Funds ,
Loan Payments ,
Non-Bank Lenders ,
Proposed Rules
The Consumer Financial Protection Bureau (CFPB) recently introduced the Dodd-Frank 1071 Small Entity Compliance Guide, an important resource for financial institutions navigating the mandates of Section 1071 of the Dodd-Frank...more