As discussed here, on June 29, Connecticut Governor Ned Lamont signed SB 1033, An Act Concerning Various Revisions to the Banking Statutes, into law. Among other things, the bill: (1) raised the small loan limit from $15,000...more
When using artificial intelligence (AI) or complex credit models, can lenders rely on the checklist of reasons provided in Regulation B sample forms for adverse action notices? According to today’s guidance issued by the...more
9/21/2023
/ Algorithms ,
Artificial Intelligence ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Applicants ,
Creditors ,
ECOA ,
Financial Institutions ,
Financial Services Industry ,
Lack of Specificity ,
Lenders ,
Machine Learning ,
Regulation B
On June 6, Nebraska Governor Jim Pillen signed into law Legislative Bill 92, which, among many other subjects, amends the Nebraska Installment Loan Act (the NILA). Previously, a license was required for a lender seeking to...more
On July 27, the Consumer Financial Protection Bureau (CFPB) released a new blog post, positing that cashflow data, broadly defined as the various inflows, outflows, and accumulated amounts in a consumer’s checking and savings...more
7/31/2023
/ Checking Accounts ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Credit Scores ,
Financial Services Industry ,
Lenders ,
Loan Repayment Issues ,
Rulemaking Process ,
Savings Accounts ,
Self-Reporting ,
Underwriting
On June 29, Connecticut Governor Ned Lamont signed SB 1033, An Act Concerning Various Revisions to the Banking Statutes, into law. As discussed here, with this bill, Connecticut joins several other states that have set strict...more
7/14/2023
/ Banks ,
Capital Requirements ,
Connecticut ,
Consumer Financial Products ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financing ,
Income Share Agreements ,
Military Lending Act ,
New Legislation ,
Refunds ,
Small Loans
As discussed here, in April 2023, Colorado introduced HB 1229 that proposed to limit certain charges on consumer loans and simultaneously opt Colorado out of sections 521-523 of the Depository Institutions Deregulation and...more
6/9/2023
/ Banks ,
Colorado ,
Consumer Financial Products ,
Depository Institutions ,
DIDMCA ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interest Rate Caps ,
Loans ,
New Legislation ,
Opt-Outs ,
Preemption ,
Usury
Today, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a policy statement purporting to summarize, in clear and simple terms, the meaning of the statutory prohibition on abusive conduct. Policy statements are...more
On March 29, the New Mexico Financial Institutions Division of the Regulation and Licensing Department’s (NM FID) new rule on the New Mexico-Annual Percentage Rate (NM-APR) becomes effective. We previously blogged about New...more