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Oregon Considering DIDMCA Opt-Out Legislation

Oregon may become the latest state attempting to stop out-of-state banks from “exporting” home-state interest rates on loans made to Oregon consumers. Like similar legislation adopted by Colorado in 2023, House Bill 2561...more

DOJ and CFPB Remind Institutions of Rate Protections for Servicemembers

The Servicemember Civil Relief Act limits the amount of interest that may be charged on certain financial obligations that were incurred before military service began to no more than 6% percent per year, including most fees...more

DC Attorney General files suit against app-based lender EarnIn

The Attorney General for the District of Columbia has filed suit against ActiveHours Inc., doing business as EarnIn, alleging that the app-based lender deceptively marketed and provided illegal high-interest loans to more...more

Plaintiffs oppose Colorado’s motion for a stay of the preliminary injunction in the Colorado opt-out litigation

Very soon, briefing by the parties in the 10th Circuit will commence with respect to Colorado’s appeal of a preliminary injunction entered by the Federal District Court for the District of Colorado. The District Court...more

FDIC Seeking Comments on Industrial Bank Rule Changes

The FDIC is seeking comment on proposed changes to its regulation governing parent companies of industrial banks and industrial loan companies—Part 354 of the FDIC Rules and Regulations....more

Colorado provides some (but not enough) guidance on new general-purpose credit card carve-out

In the same 2023 bill (House Bill 23-1229) that included Colorado’s DIDMCA opt-out**, Colorado adopted a statute excepting certain “general-purpose credit cards”, as defined, from the state’s limitations on finance charges...more

Colorado UCCC Administrator issues interpretive opinion letter regarding Colorado opt-out law

On April 22, 2024 (almost 2 months before Judge Daniel Domenico issued a preliminary injunction against the UCCC Administrator and Colorado Attorney General), Administrator Martha Fulford issued an Interpretive Opinion Letter...more

Colorado federal court issues preliminary injunction prohibiting Colorado from enforcing DIDMCA opt-out to loans made to Colorado...

The Colorado federal district court hearing NAIB, et al v. Weiser, et al., the lawsuit filed by three consumer financial services industry trade groups challenging Colorado’s opt-out legislation, has granted the plaintiffs’...more

Preliminary Injunction Hearing in Federal Court on Colorado DIDMCA Opt-Out Challenge

On May 16, the U.S. District Court for the District of Colorado held a hearing in NAIB, et al v. Weiser, et al. on a motion filed by three financial services industry trade groups to preliminarily enjoin Colorado from...more

Plaintiffs file reply in support of motion for preliminary injunction in Colorado rate exportation litigation

The industry group plaintiffs in NAIB et al. v. Weiser et al., the lawsuit challenging Colorado’s opt-out legislation, have filed their reply to the brief filed by the Colorado Attorney General and Colorado Uniform Consumer...more

Colorado rate exportation litigation: Why Colorado and the FDIC are wrong about where a loan is made for purposes of DIDMCA...

Last week, we blogged about arguments by Colorado and the FDIC in their briefs opposing a motion for preliminary injunction that would enjoin application of Colorado’s opt-out statute with respect to loans by FDIC-insured...more

Oh, won’t you stay (enforcement): Plaintiffs seek preliminary injunction in Colorado interest rate preemption opt-out challenge

Colorado’s attempt to opt out of interest rate exportation by out-of-state, state-chartered banks ultimately will fail, and will cause irreparable harm in the interim: therefore, enforcement of the opt out should be...more

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