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Consumer Financial Products Disclosure Requirements Consumer Financial Protection Bureau (CFPB)

Ballard Spahr LLP

CFPB will not issue revised BNPL rule

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Having previously announced that it was withdrawing its Buy Now, Pay Later rule, the CFPB recently said that it does not intend to issue a revised rule....more

Ballard Spahr LLP

2024 HMDA Modified Loan Application Data Published

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The CFPB has announced that Home Mortgage Disclosure Act (HMDA) Modified Loan Application Register (LAR) data for 2024 are now available on the Federal Financial Institutions Examination Council’s (FFIEC) HMDA Platform for...more

Orrick, Herrington & Sutcliffe LLP

Pennsylvania attorney general sues mortgage brokers for illegal kickback scheme

Recently, a complaint was filed by the Commonwealth of Pennsylvania, through Attorney General Michelle A. Henry (AG) in the U.S. District Court for the Eastern District of Pennsylvania, accusing a group of mortgage brokers...more

McGlinchey Stafford

FTC’s CARS Rule Vacated — What Finance Companies Need to Know

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In a procedural decision, the U.S. Court of Appeals for the Fifth Circuit vacated the CARS Rule (officially, the Combatting Auto Retail Scams Trade Regulation Rule, sometimes known as the Vehicle Shopping Rule) which was...more

Ballard Spahr LLP

CFPB orders remittance transfer provider to pay almost $2.5 million for alleged illegal activities

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On January 30, 2025, the CFPB ordered Wise, an international remittance company, to pay almost $2.5 million in connection with allegations of illegal activities, including advertising inaccurate fees and failing to properly...more

Sheppard Mullin Richter & Hampton LLP

CFPB Orders Remittance Company to Pay $2.5 Million for Deceptive Practices and Inaccurate Disclosures

On January 30, 2025, the CFPB issued an order against a remittance company for misleading consumers about fees and failing to provide accurate disclosures, harming consumers who relied on the company’s representations when...more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes CARD Act-mandated request for information

On January 17, the CFPB published in the Federal Register a Request for Information (RFI) about a number of aspects of the consumer credit card market, as mandated by the CARD Act. The RFI seeks public input to shape the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Warning on Risks of Home Equity Contracts, Takes Legal Action to Ensure Compliance with TILA

On January 17, 2024, the Consumer Financial Protection Bureau (CFPB) issued a report, consumer advisory, and filed an amicus brief addressing the risks associated with home equity contracts (HECs)—financial products often...more

Troutman Pepper Locke

New Year = New Earned Wage Access Legislation in New York

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This week, New York became the latest state to introduce legislation aimed at regulating Earned Wage Access (EWA) services. Assembly Bill 258 titled — “An Act to Amend the Banking Law, in Relation to Providing for Income...more

Morrison & Foerster LLP

Leaning In: The CFPB Publishes Rule on Fees for Overdraft Services

On December 30, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that may dramatically change the way that certain large financial institutions offer overdraft services to consumers. Under the...more

Troutman Pepper Locke

CFPB Proposes Amendments to Disclosure Requirements Under Remittance Transfer Rule

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On September 20, the Consumer Financial Protection Bureau (CFPB or Bureau) announced a proposed rule aimed at amending the disclosure requirements for international money transfers, commonly known as remittances. The proposed...more

Venable LLP

CFPB Issues FAQs: Expands Interpretive Rule for BNPL Products

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On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...more

Ballard Spahr LLP

CFPB proposes ‘narrow’ amendment to disclosure requirements for international remittances and money transfers

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The CFPB has issued a proposed rule with a small amendment to disclosure requirements for certain international remittances and money transfers....more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2024 #4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....more

Ballard Spahr LLP

In Rare Move, the CFPB Comes to the Defense of Bank

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In an unusual move, the CFPB is coming to the defense of a bank being accused of failing to provide repayment disclosures to a borrower....more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

BakerHostetler

Steering into Dark Patterns

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Sometimes you hear grumbling that Leap Day shouldn’t mean an extra day of work – but not at the CFPB. The agency celebrated Feb. 29 this year by issuing guidance regarding “steering.”...more

Ballard Spahr LLP

CFPB proposed rule would makes certain overdraft program’s credit subject to Regulation Z disclosure requirements and could cap...

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In furtherance of the Biden Administration’s “junk fee” agenda, on January 17, 2024, the Consumer Financial Protection Bureau issued its proposed rule to amend Regulations E and Z to regulate overdraft services provided by...more

Alston & Bird

Consumer Finance ABstract 2023 Year-End Reprise

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As we reflect on the previous year and look toward the new year, we thought you’d appreciate our top 20 most-read Consumer Finance ABstract posts from 2023...more

Davis Wright Tremaine LLP

Stay ADvised: Brand Protection & Advertising Law News - June 2023 - 2

Blurred Lines: NAD Says Supplement Company Must Add Conspicuous Disclosures When Editorial Content Is Advertising - Once again, the National Advertising Division has examined the increasingly blurry line between...more

Sheppard Mullin Richter & Hampton LLP

CFPB: TILA Does Not Preempt State Commercial Financial Disclosures

On March 28, the CFPB issued a preemption determination that that TILA does not preempt commercial lending disclosure regulations enacted in California, New York, Utah, and Virginia (we discussed state commercial financing...more

Orrick, Herrington & Sutcliffe LLP

CFPB: TILA does not preempt state laws on commercial financial disclosure

On March 28, the CFPB issued a determination that state disclosure laws covering lending to businesses in California, New York, Utah, and Virginia are not preempted by TILA. ...more

Ballard Spahr LLP

DC Circuit Rules CFPB Prepaid Card Rule Does Not Mandate Use of “Model Clause”

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The U. S. Court of Appeals for the D.C. Circuit held that the CFPB’s prepaid card rule (Prepaid Rule) does not mandate a “model clause.” The ruling was made in the lawsuit that PayPal, one of the largest digital wallet...more

Goodwin

DC Circuit Holds CFPB Did Not Exceed Statutory Authority with the Prepaid Rule

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​​​​​​​On February 3, 2023, the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit) issued a decision regarding the disclosure requirements of the Consumer Financial Protection Bureau’s (CFPB) Prepaid...more

Orrick, Herrington & Sutcliffe LLP

D.C. Circuit says CFPB’s Prepaid Rule does not mandate model disclosures for payment companies

On February 3, the U.S. Court of Appeals for the D.C. Circuit reversed a district court’s decision that had previously granted summary judgment in favor of a payment company and had vacated two provisions of the CFPB’s...more

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