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Bank Regulators Issue Guidance for Third-Party Risk Management

On June 6, 2023, the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) (collectively, Agencies)...more

CFPB Deems Merchant Cash Advances to Be “Credit” Under ECOA

The Consumer Financial Protection Bureau’s adopting release for its small business data collection and reporting rule goes beyond that rule by including a discussion deeming merchant cash advances to be “credit” more...more

CFPB Finalizes Small Business Lending Data Rule

On March 30, 2023, the Consumer Financial Protection Bureau (CFPB) released its small business lending data collection and reporting rule, required by Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection...more

CFPB Says Creditors Must Provide Reasons For Taking Adverse Action, Even When Relying On AI

On May 26th, 2022, the Consumer Financial Protection Bureau (“CFPB”) published a Consumer Financial Protection Circular (the “Circular”), confirming that creditors must provide specific reasons for taking adverse action...more

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