Having previously announced that it was withdrawing its Buy Now, Pay Later rule, the CFPB recently said that it does not intend to issue a revised rule....more
6/23/2025
/ Administrative Procedure Act ,
Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
Disclosure Requirements ,
Financial Regulatory Reform ,
Financial Services Industry ,
FinTech ,
New Regulations ,
Regulation Z ,
Rulemaking Process ,
Truth in Lending Act (TILA)
Alleging that a Boston company “pervasively and systematically violated the state’s consumer protection laws, including mortgage and foreclosure prevention laws, putting financially vulnerable homeowners at high risk of...more
The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is defined in the Truth in Lending Act and...more
If there was any doubt about how the Consumer Financial Protection Bureau (“CFPB”) (under current leadership) feels about what it calls “home equity contracts” (also known as shared appreciation agreements, shared equity...more
Borrowers with subprime or deep subprime credit scores make up the majority of Buy Now, Pay Later (BNPL) originations, the CFPB said, in a new report. From 2021 to 2022, borrowers with deep subprime credit scores accounted...more
1/16/2025
/ Borrowers ,
Buy Now Pay Later (BNPL) ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Credit Reports ,
Data Collection ,
Debt ,
Financial Institutions ,
Financial Services Industry
In the wake of the Office of Administrative Law’s approval of its registration and reporting requirements for providers of income-based advances, private postsecondary education financing, debt settlement services, and...more
12/3/2024
/ California ,
California Consumer Financial Protection Law (CCFPL) ,
Comment Period ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Office of Administrative Law Judges (OALJ) ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Requirements
On October 11, California’s Office of Administrative Law (“OAL”) approved the Department of Financial Protection and Innovation’s (“DFPI’s”) registration rulemaking for providers of the following products...more
11/1/2024
/ California Consumer Financial Protection Law (CCFPL) ,
Comment Period ,
Consumer Financial Products ,
Debt Settlement Services ,
Debt-Relief Industry ,
Department of Financial Protection and Innovation (DFPI) ,
Earned Wage Access ,
Financial Services Industry ,
Income Share Agreements ,
Office of Administrative Law Judges (OALJ) ,
Regulatory Agenda ,
Regulatory Requirements ,
Rulemaking Process
The CFPB has scheduled two sessions to provide a preview of its nonbank enforcement order registry. The virtual-only discussions are scheduled for September 30 and October 9. Both sessions will feature the same content....more
In April 2024, Wisconsin and Maine enacted the Model Money Transmission Modernization Law (“MTML”) to implement the Conference of State Bank Supervisors’ Model Money Transmission Modernization Act. As of April 22, 2024,...more
Maryland has joined the ranks of states considering legislation that would codify elements of “true lender” theory in an effort to impose federally preempted state licensing requirements and rate caps on loans to Maryland...more
The 11th annual report on NMLS operations, performance and new development efforts has been released by the NMLS. ...more
The North Carolina Office of the Commissioner of Banks recently updated its FAQs to specifically address the need for a Servicer license for entities that merely hold mortgage servicing rights. ...more
For those agencies that permit license reinstatement, the reinstatement period will run until midnight Eastern Time on February 28, 2019....more
An open meeting with the NMLS Ombudsman will be held Wednesday, February 20, 2019, from 9 a.m. to 12 p.m. ET, in conjunction with the 2019 NMLS Annual Conference & Training in Orlando, Florida. ...more
Registration for the 2019 NMLS Annual Conference & Training is now open. The Conference will be held February 18-21...more
A reminder that the NMLS license renewal period opened on November 1, and that there is an Annual Renewal Information section on the NMLS Resource Center website with detailed information regarding deadlines, requirements,...more
We have been following closely efforts by state regulators, state legislatures and the courts to restrict, or in some cases prohibit, bank model lending programs, so the recent guidance from the Vermont Department of...more
10/9/2018
/ Banking Sector ,
Consumer Financial Products ,
Exemptions ,
FDIC ,
Financial Institutions ,
Financial Services Industry ,
Lenders ,
Licensing Rules ,
Regulatory Oversight ,
Regulatory Requirements ,
Solicitation/Distribution Policies ,
State and Local Government
Effective immediately, Illinois Residential Mortgage licensees will no longer be required to include the phrase "Illinois Residential Mortgage Licensee" in advertisements...more
Significant changes to Connecticut’s licensing laws for consumer financial services providers will take effect on October 1, 2018. In addition to changes impacting mortgage-related licensees (e.g. mortgage lenders,...more
On July 30, 2018, an updated version of the NMLS Policy Guidebook was posted to the NMLS Resource Center. The announcement posted on the Resource Center home page states that "The updated NMLS Policy Guidebook does not...more
The NMLS Mortgage Industry Report for the first quarter of 2018 has been made available on the NMLS website (NMLS Reports). The report compiles data on mortgage companies, branches, and mortgage loan originators. ...more
In connection with the 2018 American Association of Residential Mortgage Regulators (AARMR) Annual Conference to be held in Boston, an open meeting with the NMLS Ombudsman will be held Tuesday, July 31, 2018, from 9:00 a.m....more
The Indiana Department of Financial Institutions (Department) has issued its Questions & Answers (Q&A) related to upcoming changes in various statutes administered by the Department that become effective as of July 1, 2018. ...more
The NMLS Policy Guidebook has been updated effective February 1, 2018, replacing the version issued on July 23, 2012. The announcement accompanying publication of the Guidebook notes that the updates are intended to align the...more
We are pleased to invite you to the 22nd Annual Consumer Financial Services Institute, sponsored by the Practising Law Institute, March 27-28, 2017, in New York City (and by live webcast and groupcast in Atlanta and...more
1/27/2017
/ Banking Sector ,
Class Action ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Privacy ,
Data Security ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Financial Services Industry ,
Mortgages ,
Regulatory Oversight ,
TCPA