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Georgia Enacts Commercial Financing Disclosure Law, Mandatory Compliance Date January 1, 2024

Georgia has enacted its own Commercial Financing Disclosure Law (“CFDL”) that is similar to California, Florida and New York’s disclosure laws. The Georgia CFDL applies to covered “Commercial Financing Transactions”...more

Florida Enacts Commercial Financing Disclosure Law, Mandatory Compliance Date January 1, 2024

Florida has enacted its own Commercial Financing Disclosure Law (“CFDL”) that is similar to California and New York’s disclosure laws. The Florida CFDL applies to covered “Commercial Financing Transactions” consummated on or...more

CFPB and Federal Banking Agencies Propose Quality Control Standards on Automated Valuation Models Used in Underwriting Mortgage...

On June 1, 2023, the Consumer Financial Protection Bureau along with Federal Reserve, OCC, FDIC, NCUA and FHFA (collectively, the “Agencies”) issued a Notice of Proposed Rulemaking seeking comment on rules to implement...more

NY DFS Publishes Final Regulation Implementing Article 8, New York State’s Commercial Finance Disclosure Law

Superintendent of Financial Services Adrienne A. Harris announced on February 1, 2023 that the New York State Department of Financial Services has adopted a final regulation relating to early disclosure requirements on...more

California DFPI Publishes Final Commercial Loan Disclosure Regulations

On June 9, 2022, the California Department of Financial Protection and Innovation (CA DFPI) issued its long awaited final regulations implementing SB 1235’s (2018) new early disclosure requirements on commercial financing...more

NMLS Transition Update for Existing California Financing Law Licensees: CA DFPI has Extended the Deadline for Submitting Company...

Earlier this year, we reported that the California Department of Financial Protection and Innovation (CA DFPI) published new regulations requiring all existing commercial lenders and brokers licensed under the California...more

NMLS Transition Update for Existing California Financing Law Licensees: CA DFPI Has Opened the NMLS Portal to Receive Transition...

Following July 8, 2021’s Client Alert, the California Department of Financial Protection and Innovation (DFPI) posted its CFL Transition Checklist for existing California Financing Law licensees to begin the license...more

CA DFPI Issues New Round of Proposed Rules for Transitioning Existing CA Financing Law Licensees to the NMLS Platform

Back in November 2020, we reported the CA Department of Financial Protection and Innovation (“CA DFPI”) as administrator of the California Financing Law (CFL) License had published a third round of proposed rules to...more

Buchalter COVID-19 Client Alert: DFPI Reminds Debt Collectors about Rental Protections for COVID-19 Rental Debt

Acting under its new Debt Collection Licensing Act licensing administration and enforcement authority granted by SB 908, the DFPI Commissioner issued a public statement on April 9th reminding all future license applicants...more

California DFPI Publishes Notice of Proposed Rulemaking for Debt Collector Licensing

As a follow up to my article on December 4, 2020, reporting that California enacted SB 908 – the Debt Collection Licensing Act, Financial Code Division 25, Sections 100000, et seq., the administering agency Department of...more

Revising the New General QM Final Rule and Seasoned QM Final Rule: CFPB Expected to Postpone the Mandatory Compliance Date for the...

On February 5, a Buchalter Client Alert discussed CFPB Acting Director Uejio’s announcement that he was considering delaying implementation of the two new QM Final Rules (the “General QM final rule”, which creates a new...more

Coming in 2021: CFPB Finalizes Changes to “Qualified Mortgage” Definition and Creates a New “Seasoned QM” Loan Category

Changes are coming in 2021 to the eligibility requirements for “Qualified Mortgage” or “QM” loans. The Ability-to-Repay/Qualified Mortgage Rule administered by CFPB (“ATR/QM Rule”) requires a creditor to make a reasonable,...more

California Enacts Consumer Debt Collector Licensing Administered by DFPI

During the 2019 legislative session, California enacted SB 908 – the Debt Collection Licensing Act, Financial Code Division 25, Sections 100000, et seq., requiring consumer debt collectors who are collecting on their own...more

CA DFPI One Step Closer to Finalizing CFL Commercial Loan Disclosure Regulations

The California Department of Financial Protection and Innovation (fka Department of Business Oversight) is one step closer to issuing final regulations that would impose new early disclosure requirements on covered commercial...more

Newly Enacted California Consumer Financial Protection Law (AB 1864) Reorganizes and Renames Financial Institutions Regulator for...

California has enacted a new California Consumer Protection Law (CCFPL), California Financial Code Section 90001 et seq. The CCFPL will convert the Department of Business Oversight (DBO) into a new Department of Financial...more

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