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Double Clicking on Innovation in Consumer Finance: Responsible Use of AI

Artificial intelligence (AI) is becoming ubiquitous across sectors, and the financial services industry is no exception. With the rise of AI, there is also an increase in scrutiny by regulators over its use....more

CFPB Departs From Precedent and Reverses Itself by Proposing Novel Interpretive Rule That Applies TILA and Regulation Z to...

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule (Proposed Rule) applying the Truth in Lending Act (TILA) and Regulation Z (collectively referred to hereafter as Regulation Z) to...more

The CFPB’s “Junk Fees” Initiative: Recent Developments and Trends

The term “junk fee” is not defined under federal law, but the CFPB has focused on factors such as whether the fee would be unexpected to or take advantage of a reasonable consumer, the amount of the fee compared to the cost...more

CFPB Deems Merchant Cash Advances to Be “Credit” Under ECOA

The Consumer Financial Protection Bureau’s adopting release for its small business data collection and reporting rule goes beyond that rule by including a discussion deeming merchant cash advances to be “credit” more...more

CFPB Finalizes Small Business Lending Data Rule

On March 30, 2023, the Consumer Financial Protection Bureau (CFPB) released its small business lending data collection and reporting rule, required by Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection...more

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