Does anyone else feel like Bill Murray in Groundhog Day, where his character keeps experiencing the same day over and over and over again? It seems like the Federal Trade Commission just amended the Safeguards Rule yesterday,...more
On November 1, 2023 the New York Department of Financial Services ("DFS") released amended cybersecurity regulations ("Regulations"). These changes will impose additional controls, demand more frequent risk assessments, and...more
12/1/2023
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Risk Assessment
On April 3, 2023, the Consumer Financial Protection Bureau issued a policy statement on "abusive" practices. While this is the second time the CFPB has issued a policy statement on abusiveness, the significance of this policy...more
On March 2, 2023, the CFPB released a report entitled "Consumer use of Buy Now, Pay Later: Insights from the CFPB Making Ends Meet Survey," examining Buy Now, Pay Later ("BNPL") products. BNPL products typically allow...more
On October 27, 2021, the Federal Trade Commission finalized its long-awaited updates to the Safeguards Rule. The changes require financial institutions, including auto dealers and finance companies, to dust off their existing...more
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
On October 27th, the Federal Trade Commission (“FTC”) finalized its long-awaited updates to the Safeguards Rule. The Safeguards Rule implements provisions of the Gramm-Leach-Bliley Act requiring the safeguarding of customer...more
In 2020, the Supreme Court held in Bostock v. Clayton County, Georgia that an employer who fires an employee for being gay or transgender violates the Civil Rights Act of 1964 (“Title VII”). Though the list of protected...more
[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
In July 2020, the Consumer Financial Protection Bureau ("Bureau") at long last finalized the Rule governing Payday, Vehicle Title, and Certain High-Cost Installment Loans ("Small Dollar Rule" or "Rule"). The Rule, originally...more