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CFPB Bites of the Month - 2024 Annual Review - Nondiscrimination and Military Protection Law

In this article, we share a timeline of our monthly "bites" for 2024 applicable to consumers protected by nondiscrimination and military protection laws. 2025 will likely bring more of the same, particularly in the area of...more

CFPB Bites of the Month - 2022 Annual Review - Nondiscrimination and Military Protection Laws

In this article, we share a timeline of our monthly "bites" for 2022 applicable to consumers protected by nondiscrimination and military protection laws. The CFPB has historically been particularly active with respect to...more

Thinking of Accepting Payments from Customers via Discretionary Military Allotments? Think Again.

Accepting payments via discretionary military allotments has long been suspect in the eyes of the Consumer Financial Protection Bureau. Military allotments are automatic deductions from military pay. Allotments can be...more

Stuck in a Time Loop: The Compliance Clock Is Still Ticking for Small-Dollar Lenders in 2021

During the past year, small-dollar lenders learned the fate of the Consumer Financial Protection Bureau’s (“CFPB”) final rulemaking addressing payday, vehicle title, and certain high-cost installment loans. In addition, the...more

Tik Tok: The Compliance Clock Is Ticking for Small-Dollar Lenders in 2020

[co-author: Hurshell K. Brown - Beyond Finance, LLC] INTRODUCTION - Small-dollar lenders waited through most of 2020 for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rulemaking addressing payday, vehicle...more

CFPB Announces Broad Military Lending Act Compliance Sweep

On December 4, 2020, the Consumer Financial Protection Bureau announced the filing of a lawsuit against an online lender for allegedly violating the Military Lending Act ("MLA"). The CFPB's complaint alleges that the lender...more

Equality in Credit Decisions - Does "Sex" include Sexual Orientation and Gender Identity?

In June of this year, the United States Supreme Court held that an employer who fires an employee for being gay or transgender violates the Civil Rights Act of 1964 ("Title VII"). Title VII prohibits employers from refusing...more

Small Dollar Lending Regulation in 2019

One year ago, small dollar lenders were operating under the specter of looming compliance dates for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rule concerning small dollar lending. One year later, through...more

New Policy on Prohibition of Abusive Acts or Practices - What do you need to know?

In 2010, the Dodd-Frank Act for the first time made it unlawful for persons to engage in an “abusive act or practice.” The “abusive” standard was added to the existing “UDAP” standard—unfair, deceptive acts and practices,...more

The Walking Dead: 2018 Small Dollar Lending Updates-Is the Small Dollar Loan Industry Mostly Dead or Slightly Alive?

During the past year, many small dollar lenders operated under looming rulemaking from the Bureau of Consumer Financial Protection (“CFPB”), which threatened elimination of their businesses. This survey reviews small dollar...more

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