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Consumer Financial Products › Disclosure Requirements › Rulemaking Process

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

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

Snell & Wilmer

FTC Click to Cancel Rule

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In 2023, the U.S. Federal Trade Commission (FTC) sought public comments on how to combat perceived unfair and deceptive trade practices, recurring subscription charges, and cancelation of such plans. Born out of these...more

Sheppard Mullin Richter & Hampton LLP

Consumer Fees Find Themselves in the Crosshairs: The CFPB Seeks Public Input on Alleged “Junk Fees” in the Consumer Financial...

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The Consumer Financial Protection Bureau (“CFPB”) has continued to ratchet up its regulatory scrutiny over the consumer financial services market. On January 26, 2022, the CFPB published an initiative seeking public input on...more

Mayer Brown

FDIC Adopts Changes to Securitization Safe Harbor Rule

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Since its adoption in 2010, the Federal Deposit Insurance Corporation’s (the “FDIC”) securitization safe harbor rule, 12 C.F.R. § 360.6 (the “Rule”), which relates to the treatment of financial assets transferred in...more

Ballard Spahr LLP

Georgia and Colorado Address MLO Temporary Authority to Operate

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Following receipt and consideration of three written comments on proposed rules distributed on November 18, 2019, the Georgia Department of Banking and Finance adopted final rules on December 20, 2019, that establish...more

Ballard Spahr LLP

CFPB to Assess TRID Rule’s Effectiveness

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The Dodd-Frank Act requires the CFPB to conduct an assessment of each “significant rule” adopted by the Bureau. The Bureau has determined that the TILA/RESPA Integrated Disclosure (TRID) Rule qualifies as a “significant...more

Ballard Spahr LLP

Prepaid account agreements database now on CFPB website

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The CFPB’s final rule on prepaid accounts, which became effective on April 1, 2019, requires issuers of prepaid accounts, with certain exceptions, to submit to the CFPB all account agreements that the issuer offers, amends,...more

Ballard Spahr LLP

CFPB Updates TRID Rule FAQs to Address Providing a Loan Estimate to Consumers

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The CFPB recently updated the TRID rule FAQs to address questions about providing a Loan Estimate to consumers. The FAQs mostly confirm guidance previously provided by the CFPB in various forms. ...more

Ballard Spahr LLP

CFPB Releases Implementation Materials for Submission of Prepaid Account Agreements

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Wednesday, the Consumer Financial Protection Bureau (CFPB) released guidance and technical specifications relating to the submission of prepaid account agreements. ...more

Ballard Spahr LLP

CFPB clarifies coverage of “disclosure sandbox” proposal; consumer groups comment on proposed revisions to no-action letter policy...

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“Disclosure Sandbox.”  In September 2018, the Bureau proposed significant revisions to its “Policy to Encourage Trial Disclosure Programs” which sets forth the Bureau’s standards and procedures for exempting individual...more

Ballard Spahr LLP

April 1 effective date of prepaid rule leaves little remaining time for addressing significant compliance challenges

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After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019. ...more

Ballard Spahr LLP

CA regulator invites comments on proposed rulemaking to implement new law requiring commercial financing disclosures

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The California Department of Business Oversight (DBO) has issued an invitation for comments from stakeholders in developing regulations to implement SB 1235, the bill signed into law on September 30, 2018 that requires...more

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