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California Home Improvement and Solar Financing Bill Passed by Senate and Moving Through Assembly

An initiative designed to add significant regulatory obligations to the home improvement and solar financing industries is progressing through the California legislature. Senate Bill 784 (SB 784) passed the California Senate...more

CFPB Shifts Focus Away from Buy Now, Pay Later Loans

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

Texas Introduces Legislation to Regulate Sales-Based Commercial Financing

Last month, the Texas legislature introduced two companion bills, S.B. No. 2677 and H.B. No. 700, to regulate sales-based commercial financing. For purposes of the proposed legislation, sales-based financing is a transaction...more

Alaska Proposes Amendments to Small Loan Act Targeting Banking-as-a-Service Programs

On January 10, the Alaska Legislature introduced Senate Bill 39 that aims to amend the state’s Small Loan Act. This proposed legislation seeks to implement significant changes, including the introduction of a predominant...more

Colorado Federal Court Enjoins State Enforcement of DIDMCA Opt-Out Legislation Against Out-Of-State Lenders

On June 18, a Colorado federal court granted the plaintiff trade groups’ motion for a preliminary injunction, effectively halting the enforcement of Colorado’s H.B. 1229 with respect to loans made by out-of-state...more

CFPB Files Lawsuit Against SoLo Funds for Alleged Deceptive Lending Practices

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a complaint against SoLo Funds, Inc., a fintech company operating a small-dollar, short-term lending platform. The CFPB alleges that SoLo Funds...more

Maryland is Latest State to Introduce Legislation Targeting Bank Partnership Programs

On January 10, HB 254, entitled the True Lender Act, was introduced before the Maryland House of Delegates. The Act would amend the Maryland Commercial Law to add an article containing both predominant economic interest and...more

NY Governor Announces Plans to Regulate “Buy Now, Pay Later” Industry

On January 2, New York Governor Kathy Hochul unveiled her 2024 consumer protection agenda, which includes plans to regulate the “buy now, pay later” (BNPL) industry. Specifically, Governor Hochul plans to propose legislation...more

Washington State Representatives Propose Amendments Targeting Bank Model Lending and Loan Programs Based on Tips or Memberships

Washington now joins the list of states that have enacted or proposed legislation adopting so-called anti-evasion provisions, including legislation passed in Minnesota, Connecticut, Nebraska, and proposed in Florida. On...more

OCC Issues “Buy Now, Pay Later” Guidance to Banks

This week, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are...more

Florida Senator Introduces Bill Regulating Bank Model Lending and Loan Programs Based on Voluntary Tips

On October 9, a Florida state senator introduced SB 146, which would add a new section to the Florida Consumer Finance Act (CFA), attempting to curb evasion of the CFA. SB 146 would treat all payments incident to the loan as...more

Opportunity Financial Scores Big Win in CA DFPI’s “True Lender” Lawsuit

A California state court recently denied a preliminary injunction sought by the California Department of Financial Protection and Innovation (the DFPI) in its long-running litigation against Opportunity Financial (OppFi)...more

Federal Agencies Finally Weigh in on Immigration Status in Credit Underwriting

Last week, the U.S. Department of Justice (DOJ) and the Consumer Financial Protection Bureau (CFPB) (collectively, the agencies) issued a joint statement on the subject of creditors’ use of immigration status for eligibility...more

Nebraska Enacts Loan Licensure Requirement for Marketers, Servicers and Purchasers of Interests in Certain Bank Loans

On June 6, Nebraska Governor Jim Pillen signed into law Legislative Bill 92, which, among many other subjects, amends the Nebraska Installment Loan Act (the NILA). Previously, a license was required for a lender seeking to...more

CFPB Focuses on Medical Credit Cards and Installment Loans in Latest Report

Citing research that found about half of U.S. adults find it difficult to afford the cost of their healthcare, the Consumer Financial Protection Bureau (CFPB or Bureau) published a report focusing on medical credit cards and...more

Texas Bankers Challenge CFPB’s Section 1071 Rule

On April 26, the Texas Bankers Association and Rio Bank, McAllen, Texas filed a complaint in the U.S. District Court for the Southern District of Texas challenging the Consumer Financial Protection Bureau’s (CFPB or Bureau)...more

CFPB Continues to Press for Expanded Definition of Credit Transaction Under ECOA by Interjecting its Position in Pending Private...

On April 14, the Consumer Financial Protection Bureau (CFPB) submitted a statement of interest to the U.S. District Court for the Southern District of Florida arguing that the Equal Credit Opportunity Act’s (ECOA) prohibition...more

New Mexico Enacts 36% APR Cap on Loans of $10,000 or Less

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

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