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Washington state “predatory loan” bills propose expanded coverage, “anti-evasion” language, licensing revisions, and other...

House Bill 1874 (H.B. 1874), denominated the “predatory loan prevention act”, was pre-filed for introduction in the Washington state legislature December 5, 2023, and referred to the House Committee on Consumer Protection and...more

Rate Exportation Opt-Out and “Anti-Evasion” Bill Introduced in Washington D.C.

District of Columbia Council Bill B 25-0609, which would opt out of Section 27 of the Federal Deposit Insurance Act (“FDIA”) with respect to loans made in the District of Columbia, was introduced in the District of Columbia...more

Predatory Loan Prevention Bill Introduced in Florida to Codify “True Lender” Analysis

Florida SB 146, a bill that would add a “Predatory loan prevention” section to the Florida Consumer Finance Act has been introduced in the Florida Senate, seeking to curb bank-model lending programs and codify a “true lender”...more

CFPB issues proposal to supervise nonbank providers of digital wallets and payment apps

The CFPB has issued a proposed rule to supervise nonbank companies that qualify as larger participants in a market for “general-use digital consumer payment applications.”  Comments on the proposal are due by January 8, 2024...more

Federal Reserve Considering Lowering Debit Card Interchange Fee Caps (UPDATED)

As we previously blogged, the Board of Governors of the Federal Reserve (the “Board”) held an open meeting on October 25, 2023 to discuss the debit card interchange fee cap. The debit card interchange fee cap was part of the...more

Federal Reserve considering revisions to debit card interchange fees

The Board of Governors of the Federal Reserve (FRB) is holding an open meeting on October 25, 2023 to discuss proposed revisions to the Board’s debit interchange fee cap contained in Regulation II, which implemented the...more

Missouri joins state efforts to regulate earned wage access providers

On August 28, 2023 (the “Effective Date”), SB 103, signed into law by Missouri’s governor, will become the nation’s second statutory framework for earned wage access (EWA) providers.  The Missouri law closely resembles...more

CFPB credit card late fees proposal published in Federal Register

Nearly two months after it was issued on February 1, the CFPB’s proposal to make significant changes to the Regulation Z rules for credit card late fees was published in today’s Federal Register. The changes include a...more

OCC issues proposed “true lender” rule

Less than two months after issuing its final “Madden fix” rule, the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a...more

Prepaid account agreements database now on CFPB website

The CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends,...more

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