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Alternative Commercial Finance Monthly | February 2025

Last month, we reported several laws scheduled to take effect this year. The first was the Commercial Financing Disclosure Law in Missouri. We have previously summarized this statute for commercial finance brokers who engage...more

CFPB's Proposed Data Broker Rule: A Sweeping Rewrite of the Fair Credit Reporting Act Regulations That Will Be Left to New CFPB...

On December 3, 2024, the Consumer Financial Protection Bureau (CFPB) published its highly anticipated notice of proposed rulemaking (NPRM) that would regulate data brokers and the sale of Americans’ personal and financial...more

Missouri Enacts New Commercial Finance Disclosure Law

Missouri is now part of the growing list of states who have introduced commercial finance disclosure requirements. Additionally, the statute – Section 427.300 of Missouri Senate Bill 1359 – contains substantial requirements,...more

CFPB Targets Mortgage Closing Costs as Junk Fees

On March 8, 2024, the CFPB issued a blog post signaling a new front in its focus on “junk fees”—mortgage closing costs. Notably, the CFPB suggests that title insurance, credit report and appraisal, origination, and other...more

Mark Your Calendars: Key 2024 Compliance Dates for Consumer and Small Business Financial Services Regulations

One of the primary challenges with working in U.S. financial services is keeping up with the ever-changing federal and state regulatory landscape. Juggling the day-to-day fire drills while staying atop of regulatory changes...more

CFPB Issues New Guidance for AI-Driven Credit Decisions

On September 19, 2023, the Consumer Financial Protection Bureau (CFPB) issued new guidance outlining lenders’ obligations under the Equal Credit Opportunity Act (ECOA) and Regulation B when using artificial intelligence (AI)...more

Court Finds Solar Energy Company Is Subject to California Rosenthal FDCPA Claim

On August 30, 2023, the California Court of Appeals addressed whether the Rosenthal Fair Debt Collection Practices Act (Rosenthal FDCPA) protects a non-party to an agreement to pay for electricity produced by a solar energy...more

CFPB Signals New Proposed Rule on Nonbank Supervision in the Consumer Payments Market

The Consumer Financial Protection Bureau (CFPB) recently released its Spring 2023 rulemaking agenda, signaling an expansion of its supervisory authority over the payments market. Of particular interest is the introduction of...more

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