Natasha Dempsey

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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

4/28/2023  /  Amended Regulation , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Credit , Creditors , ECOA , Financial Services Industry , Internet Retailers , Regulation B , Retailers

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

6/6/2022  /  Adverse Action , Algorithms , Artificial Intelligence , Consumer Financial Protection Act (CFPA) , Consumer Financial Protection Bureau (CFPB) , Consumer Lenders , Creditors , ECOA , Lenders , Regulation B
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