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Consumer Financial Products Contract Terms Financial Services Industry

Jones Day

New York Legislature Passes Bill Banning Rent Minimum Provisions in Real Estate Loan Documents

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On June 13, both houses of New York's legislature passed a bill, S1163, that prohibits "rent minimums" in real estate secured loan documents....more

Ballard Spahr LLP

Is the ‘Clarified’ AAA Clause Registration Rule Clear Enough?

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Effective May 1, 2025, the American Arbitration Association (“AAA”) amended its Consumer Arbitration Rules, including Rule 12 dealing with the registration of consumer arbitration clauses. The AAA stated that its goal was to...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: How to Use the Restatement of Consumer Contracts - A Guide for Judges

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Today’s podcast show features a discussion with Professor Gregory Klass of Georgetown University Law School about an article he co-authored with Professor Ian Ayres, entitled “How to Use the Restatement of Consumer Contracts:...more

Hudson Cook, LLP

New York Courts Appear Skeptical of Certain Fees in Sales-Based Financing Transactions

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On February 11, 2025, the Supreme Court of New York, Nassau County, ordered a hearing on whether a financing contract between Square Funding LLC and Walsh Roofing Services of Tampa Bay, LLC, was a "merchant cash advance"...more

Mayer Brown

Subscription Credit Facilities: The Importance of an Investor’s Agreement to Fund Without “Setoff, Counterclaim or Defense”

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EXECUTIVE SUMMARY - Subscription credit facilities rely on the obligations of investors to a private investment fund (“Fund”) to contribute their capital commitments to the Fund when called. From a subscription credit...more

White & Case LLP

CFPB’s Proposed Rule Aims to Prohibit the Use of Certain Contractual Provisions in Consumer Financial Products or Services...

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Background, Purpose, and Structure of the Proposed Rule - On January 13, 2025, the Consumer Financial Protection Bureau (CFPB) published a proposed rule, which aims "to prohibit certain contractual provisions in agreements...more

Orrick, Herrington & Sutcliffe LLP

CFPB issues new proposal to ban certain financial contract terms

On January 13, the CFPB proposed a new rule to ban large banks and consumer finance companies from using certain contractual provisions in agreements with consumers under Regulation AA. The CFPB’s proposal warns against the...more

Venable LLP

CFPB's Proposed Rule Targets Consumer Financial Contracts

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The Consumer Financial Protection Bureau (CFPB) issued a proposed rule under Regulation AA to address the use of restrictive and coercive clauses in consumer financial contracts. This proposal seeks to prohibit terms in...more

Ballard Spahr LLP

CFPB proposes rule to ban consumer contract terms bureau says limit ‘fundamental freedom’

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The CFPB has published a proposed rule that would ban companies from using contract clauses that the bureau said limit fundamental freedom, including those that waive a consumer’s legal rights and fine print that suppresses...more

Kilpatrick

Mind the Fine Print: CFPB Warns Against Use of Unenforceable Terms and Conditions

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In a move that underscores the importance of clarity and accuracy in consumer-facing terms and conditions, the Consumer Financial Protection Bureau recently issued Circular 2024-03, addressing the use of unlawful or...more

Wilson Sonsini Goodrich & Rosati

Avoiding Pitfalls in Consumer Financial Services Contracts: CFPB Warns Against Unlawful and Unenforceable Fine Print Terms

Companies that provide consumer financial services and products be warned—a careful review of your fine print may be in order. Although broad disclaimers, liability waivers, and releases tend to be commonplace in general...more

Orrick, Herrington & Sutcliffe LLP

CFPB cautions against unenforceable contract terms and conditions

On June 4, the CFPB issued Circular 2024-03, which cautioned covered persons under the CFPA against contracts for consumer financial products or services, including illegal or non-binding clauses. The Bureau said that such...more

Sheppard Mullin Richter & Hampton LLP

CFPB Circular Targets “Deceptive” Fine Print

On June 4, the CFPB issued a circular targeting the deceptive use of fine print in consumer financial contracts to include unlawful or unenforceable terms. In a press release issued the same day, the CFPB stressed that these...more

Troutman Pepper Locke

Contract Terms and Conditions Come Under CFPB Scrutiny

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The Consumer Financial Protection Bureau (CFPB or Bureau) has issued a circular warning covered persons that including unlawful or unenforceable terms and conditions in consumer contracts can violate the prohibition on...more

Ballard Spahr LLP

CFPB issues UDAAP guidance on contracts for consumer financial products and services

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On June 4, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued a Consumer Financial Protection Circular 2024-03 (“Circular”) warning that the use of unlawful or unenforceable terms and conditions in contracts for...more

Shipkevich PLLC

CFPB Proposed New Rule to Establish Public Registry of “Take It Or Leave It” Contract Terms and Conditions

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On January 11, 2023, the Consumer Financial Protection Bureau (CFPB) proposed a new rule to apparently shed light on the dark corners of the financial industry. The proposed rule would create a public registry of the fine...more

Hudson Cook, LLP

SDNY Holds that Revenue-Based Financing Contract is Not a Loan

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After a series of adverse decisions against revenue-based financing providers, the U.S. District Court for the Southern District of New York has given one provider a decisive victory and, in so doing, given the industry...more

Proskauer - Minding Your Business

Ninth Circuit Splits From the Second, Third and Fourth Circuits in “Brain Twister” Arbitration Case

Arbitration provisions are common features of commercial agreements.  Arbitration is often touted as a cost-effective alternative to litigation that provides contract parties the freedom to decide everything from what law the...more

Morgan Lewis

FINRA Member Firms Promptly Should Review Predispute Arbitration Provisions in Customer Agreements

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Pursuant to FINRA Regulatory Notice 21-16 that was issued on April 21, 2021, FINRA has observed certain practices that could subject firms to disciplinary action concerning predispute arbitration provisions in customer...more

Bilzin Sumberg

Residential Mortgage Originators Facing Increasing Pressures In the Midst of the Coronavirus Pandemic

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Mortgage loan brokers, correspondents and loan originators (“Originators”) who survived (or, in many cases, are still dealing with) the onslaught of “repurchase/indemnification” claims asserted by loan aggregators and...more

Hinshaw & Culbertson - Consumer Financial...

Consumer Law Hinsights – April 2020

Welcome to Consumer Law Hinsights?a monthly compilation of nationwide consumer protection cases of interest to financial services and accounts receivable management companies. This edition highlights our interactive COVID-19...more

Hogan Lovells

Impact of coronavirus on loans in Italy

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We describe below the legal impact on Italian loan transactions of the current health emergency caused by COVID-19 in light of the latest legislative measures, including a suspension of interest and principal payments on...more

Hogan Lovells

Consumer finance regulatory news, March 2020

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The Financial Conduct Authority (FCA) has published research into mortgage switching and how consumers can be encouraged to seek out better deals. It has also published occasional paper 54, which looks at the characteristics...more

Orrick, Herrington & Sutcliffe LLP

L'Efficacia della clausola floor nei contratti di finanziamento

“Nel contratto di mutuo non è giuridicamente configurabile un tasso di interesse negativo che incida sul capitale mutuato. Conseguentemente, quando il tasso d’interesse sia stato pattuito in misura variabile, esso non può...more

Ballard Spahr LLP

CA DBO concludes certain point-of-sale financing arrangements are loans, not credit sales

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On December 30, 2019, the California Department of Business Oversight (DBO) announced two actions regarding companies offering unregulated, point-of-sale financing to California residents.  In the first action,  the DBO...more

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