As part of an omnibus 2026 budget bill, New York passed a new law that will broadly govern point-of-sale (POS) installment financing offered to New York residents. The Buy-Now-Pay-Later (BNPL) Act was signed into law in early...more
6/26/2025
/ Buy Now Pay Later (BNPL) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Disclosure Requirements ,
Financial Institutions ,
Financial Services Industry ,
Installment Agreements ,
Lenders ,
New Legislation ,
New York ,
NYDFS ,
Regulatory Requirements ,
Truth in Lending Act (TILA)
One of the primary challenges with working in the U.S. financial services space is keeping up with the ever-changing federal and state regulatory landscape. Juggling the day-to-day fire drills while staying atop of regulatory...more
1/13/2025
/ Anti-Discrimination Policies ,
California ,
Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Reports ,
Data Collection ,
Data Privacy ,
Debt Collection ,
Fair Credit Reporting Act (FCRA) ,
FDIC ,
Fees ,
Financial Institutions ,
Financial Services Industry ,
Medical Debt ,
Payday Loans ,
Regulatory Agenda ,
Regulatory Requirements ,
Small Business ,
TCPA
In the closing months of the Consumer Financial Protection Bureau (CFPB) under Director Rohit Chopra, the CFPB has continued its efforts to influence how states regulate financial services providers. On November 12, the CFPB...more
12/5/2024
/ Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Privacy Rights ,
Credit Reports ,
Data Collection ,
Data Privacy ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
GLBA Privacy ,
Interpretive Rule ,
Medical Debt ,
State Privacy Laws ,
UDAAP
Yesterday, the Consumer Financial Protection Bureau (CFPB) released an interpretive rule stating that “Buy Now, Pay Later” (BNPL) providers are “card issuers” and “creditors” under the federal Truth in Lending Act (TILA) and...more
After much anticipation, the Consumer Financial Protection Bureau (CFPB) has issued a final rule drastically reducing Regulation Z’s safe harbor fee amount for credit card late fees to $8 for card issuers that do not qualify...more
In January, New York Governor Kathy Hochul introduced a budget bill that proposed the headline-grabbing Buy Now Pay Later licensing regime. Less attention has been given to another proposed provision: adding a prohibition on...more
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
1/4/2024
/ Annual Percentage Rate (APR) ,
Anti-Discrimination Policies ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Data Security ,
Federal Trade Commission (FTC) ,
Financial Institutions ,
Financial Services Industry ,
Late Fees ,
Loans ,
Regulatory Agenda ,
Small Business
What seems to have become a perennial topic for regulators, the Office of the Comptroller of the Currency (OCC) recently released OCC Bulletin 2023-37 to assist national banks and federal savings banks with effectively...more
On November 13, 2023, a nonbank lender and the Colorado Administrator of the Uniform Consumer Credit Code (Administrator) entered into an Assurance of Discontinuance to settle allegations that the lender charged membership...more
On October 18, a bill was introduced in the Illinois legislature that, if enacted, would require medical providers to provide certain disclosures to patients when referring them to third-party medical financing plans. If...more
The Consumer Financial Protection Bureau (CFPB) and the Department of Justice (DOJ) have issued a new joint statement focused on anti-discrimination in lending practices as they relate to noncitizens. This guidance not only...more
10/25/2023
/ Assessment ,
Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Discrimination ,
Department of Justice (DOJ) ,
ECOA ,
Fair Lending ,
Immigration Status Discrimination ,
Joint Statements ,
Non-Citizens ,
Regulation B
Last month, a cardholder filed a class action lawsuit in California against a national bank alleging that the bank failed to inform the consumer that his automatic payment enrollment would be canceled after a period of credit...more
10/6/2023
/ Automatic Enrollment ,
Bank of America ,
Banks ,
California ,
Class Action ,
Consumer Financial Protection Bureau (CFPB) ,
Consumers Legal Remedies Act ,
Credit Cards ,
Credit Reports ,
False Advertising ,
Financial Institutions ,
Unfair Competition
On August 2, 2023, the California Department of Financial Protection and Innovation (DFPI) issued a final rule that prohibits certain persons from engaging in unfair, deceptive, or abusive acts or practices (UDAAP) in...more
8/30/2023
/ California ,
California Consumer Financial Protection Law (CCFPL) ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Financial Protection and Innovation (DFPI) ,
Disclosure Requirements ,
Dodd-Frank ,
Farms ,
Federal Trade Commission (FTC) ,
FTC Act ,
Reporting Requirements ,
Small Business ,
State and Local Government ,
Unfair or Deceptive Trade Practices
The Consumer Financial Protection Bureau (CFPB) has been at the forefront of discussions surrounding the evolving role of data brokers in today’s digital economy. In particular, Director Rohit Chopra recently announced that...more
Minnesota has expanded its fair lending statute to prohibit discriminating against a person in the extension of credit or in the requirements of obtaining credit because of gender identity. Prior to this amendment, the...more
On March 8, the Consumer Financial Protection Bureau (CFPB) published a special edition of its Supervisory Highlights report that focused on back-end fees charged to consumers in connection with deposits, auto servicing,...more
On February 1, 2023, the Consumer Financial Protection Bureau (CFPB) proposed a rule that would dramatically decrease the late payment fee amount that card issuers could charge on credit cards and qualify for a safe harbor...more
Without its typical fanfare, the CFPB has revealed a plan to propose a rule titled “Nonbank Registration – Terms and Conditions” in its “Agency Rule List - Fall 2022.” The description of the proposed rule is scant, a mere...more
On December 7, 2022, the Consumer Financial Protection Bureau (CFPB) issued a notice for public comment on its preliminary determination that the federal Truth-in-Lending Act (TILA) does not preempt the New York Commercial...more