The Consumer Financial Protection Bureau (CFPB or Bureau) announced a significant shift in its enforcement priorities, choosing not to prioritize actions related to Buy Now, Pay Later (BNPL) loans under the Truth in Lending...more
5/9/2025
/ Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Enforcement Priorities ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Lenders ,
Loans ,
Military Service Members ,
Regulation Z ,
Small Business ,
Veterans
As part of a flurry of last minute regulatory activity by the Biden administration’s Consumer Financial Protection Bureau (CFPB or Bureau), on January 15, the CFPB published an advisory opinion in the Federal Register...more
1/23/2025
/ Advisory Opinions ,
Biden Administration ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Earned Wage Access ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Payroll Deductions ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA)
On January 13, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report providing its analysis of the growth and impact of Buy Now, Pay Later (BNPL) loans in the United States since 2019. BNPL loans,...more
This week, New York became the latest state to introduce legislation aimed at regulating Earned Wage Access (EWA) services. Assembly Bill 258 titled — “An Act to Amend the Banking Law, in Relation to Providing for Income...more
1/10/2025
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Disclosure Requirements ,
Earned Wage Access ,
Financial Regulatory Reform ,
Financial Services Industry ,
New York ,
NYDFS ,
Proposed Legislation ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA) ,
Wages
In this episode of The Consumer Finance Podcast, Chris Willis is joined by Partners Mark Furletti and Jason Cover to delve into the CFPB's recent interpretive rule that classifies buy now, pay later (BNPL) products as credit...more
Health care providers often find themselves in the position of collecting direct payments for medical services through patient payment plans. While providers must adhere to a myriad of health care laws when doing so, they...more
10/4/2024
/ Creditors ,
Financial Services Industry ,
Health Care Providers ,
Health Insurance ,
Healthcare ,
Medical Debt ,
Patients ,
Payment Plans ,
Regulation Z ,
Regulatory Requirements ,
Truth in Lending Act (TILA)
On September 18, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a set of frequently asked questions (FAQs) providing guidance on applying Regulation Z requirements to Pay-in-Four Buy Now, Pay Later (BNPL)...more
9/20/2024
/ Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interpretive Rule ,
Payday Loans ,
Regulation Z ,
Truth in Lending Act (TILA)
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...more
7/22/2024
/ Borrowers ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Earned Wage Access ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Payday Loans ,
Proposed Rules ,
Regulation Z ,
Truth in Lending Act (TILA) ,
Wage and Hour ,
Wages
In this special crossover episode of The Consumer Finance Podcast and Payments Pros Podcast, Chris Willis and Josh McBeain interview two colleagues who delve into the Consumer Financial Protection Bureau’s (CFPB) recent...more
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an “interpretive rule,” subjecting “Buy Now, Pay Later” (BNPL) transactions to provisions of Regulation Z applicable to “credit cards.” Among other...more
5/23/2024
/ Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Debt Collection ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interpretive Rule ,
Regulation Z ,
Truth in Lending Act (TILA)
On January 9, a group of five bi-partisan South Carolina Senators introduced Bill 910, which would, among other things, require persons (non-bank lenders) providing “consumer installment loans” or “deferred presentment loans”...more
1/29/2024
/ Ability-to-Repay ,
Borrowers ,
Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Financial Regulatory Reform ,
Financial Services Industry ,
Loans ,
Non-Bank Lenders ,
Payday Loans ,
Proposed Legislation ,
Regulation Z
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with request for public comment to prohibit covered financial institutions from charging nonsufficient funds fees (NSF) for payment...more
1/29/2024
/ Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Insufficient Funds ,
Overdraft Fees ,
Popular ,
Proposed Rules ,
Regulation Z ,
Regulatory Agenda ,
Rulemaking Process ,
Truth in Lending Act (TILA)
On January 17, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with request for public comment to amend exemptions to Regulation Z so the Truth in Lending Act (TILA)/Regulation Z would apply...more
1/19/2024
/ Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Fees ,
Financial Regulatory Reform ,
Financial Services Industry ,
Insufficient Funds ,
Overdraft Fees ,
Proposed Rules ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA)
In March 2023, the California Department of Financial Protection and Innovation (DFPI) proposed new regulations under the California Financing Law that would update the definition of loan to include what it dubs as...more
12/7/2023
/ California ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Financial Protection and Innovation (DFPI) ,
Employees ,
Financial Services Industry ,
Loans ,
New Regulations ,
Regulation Z ,
Truth in Lending Act (TILA) ,
Wage and Hour ,
Wages
On January 1, 2023, House Bill 132 went into effect enacting a 36% annual percentage rate (APR) cap on loans up to $10,000 made under the New Mexico Bank Installment Loan Act of 1959 and the New Mexico Small Loan Act (SLA)....more
On October 13, the Consumer Financial Protection Bureau, the Federal Reserve Board, and the Office of the Comptroller of the Currency announced increased dollar thresholds used to determine whether certain consumer credit and...more