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Consumer Financial Products Financial Regulatory Reform Non-Bank Lenders

Ballard Spahr LLP

CFPB Seeks Comments On Raising ‘Larger Participant’ Thresholds

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On August 8, 2025, the Consumer Financial Protection Bureau (“CFPB”) issued four advance notices of proposed rulemaking (“ANPR”) inviting comments on whether it should substantially reduce the number of nonbank companies the...more

Troutman Pepper Locke

NYC Comptroller Requested Stronger Protections for New Yorkers Amidst Attenuated CFPB Authority

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New York City Comptroller Brad Lander released a report titled “Standing Up for New York Consumers – How New York State and New York City can Strengthen Consumer Financial Protection in the Trump Era,” which called for the...more

Ballard Spahr LLP

Trump signs resolution voiding CFPB large nonbank supervision rule

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President Trump has signed a resolution nullifying the rule implementing the CFPB’s power to supervise large nonbank financial services providers of general-use digital consumer payment applications....more

Troutman Pepper Locke

The Reversals Continue: CFPB Proposes Rescission of Supervisory Designation Amendments

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On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This...more

Troutman Pepper Locke

CFPB Proposes Rescission of Nonbank Registration Rule

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Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry....more

Ballard Spahr LLP

CFPB rescinds enforcement, supervisory priority documents, outlines new priorities for 2025

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The CFPB is rescinding its existing enforcement and supervision priority documents, according to a memo sent to bureau staff by CFPB Chief Legal Officer Mark Paoletta....more

Brownstein Hyatt Farber Schreck

CFPB Publishes Final Nonbank Registry Rule

On June 3, the Consumer Financial Protection Bureau (CFPB) published a final rule to create a registry of nonbank companies that have entered into consent agreements or who have otherwise been found by the bureau to be in...more

Orrick, Herrington & Sutcliffe LLP

RegFi Episode 29: The CFPB’s Expanding Supervisory Authority of Fintechs and Other Non-Banks

In our latest look at the CFPB’s expanding supervisory authority of fintechs and other non-bank financial service providers, RegFi cohosts Jerry Buckley and Sasha Leonhardt welcome fellow Orrick partner — and former deputy...more

Ballard Spahr LLP

FDIC Chairman Gruenberg issues remarks at National Community Reinvestment Coalition on FDIC’s economic inclusion strategy

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FDIC’s Chairman Martin J. Gruenberg recently gave remarks at the National Community Reinvestment Coalition on the FDIC’s economic inclusion strategy.  ...more

Ballard Spahr LLP

House members urge CFPB to define “risk to consumers” in procedural rule on risk-based supervisory authority

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A bi-partisan group of House members has sent a letter to CFPB Director Chopra to express concern about the CFPB’s rule setting forth its procedures for establishing supervisory authority over nonbanks engaged in conduct that...more

Troutman Pepper Locke

South Carolina Proposes Legislation to Impose Ability-to-Repay Analysis for Installment and Payday Loans

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On January 9, a group of five bi-partisan South Carolina Senators introduced Bill 910, which would, among other things, require persons (non-bank lenders) providing “consumer installment loans” or “deferred presentment loans”...more

Cadwalader, Wickersham & Taft LLP

CFPB Issues Proposed Rule on Form Contracts

The Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule last week addressing the “Registry of Supervised Nonbanks that Use Form Contracts to Impose Terms and Conditions that Seek to Waive or Limit Consumer...more

Akerman LLP

CFPB Proposes Non-Bank Registration System for Reporting of Enforcement Orders

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On December 12th, the CFPB proposed to establish a registration system to catalog regulatory actions involving non-bank providers of consumer financial products and services brought by federal and state regulators.  The...more

Morgan Lewis - All Things FinReg

Members of Congress Introduce Joint CRA Resolution to Overturn the OCC’s True Lender Rule

Senator Chris Van Hollen (D-MD) introduced a Congressional Review Act (CRA) resolution of disapproval on March 26 that would invalidate the Office of the Comptroller of the Currency’s (OCC’s) true lender final rule. ...more

Orrick, Herrington & Sutcliffe LLP

States Seek to Invalidate The OCC True Lender Rule

Recently, seven states (New York, California, Colorado, Massachusetts, New Jersey, Minnesota, and North Carolina) and the District of Columbia filed suit in the Southern District of New York against the Office of the...more

Mayer Brown

State Prudential Standards for Mortgage Servicers: “Ahead of the Curve” or “Dead Man’s Curve”?

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I was only 9 years old when Jan and Dean in 1963 released their hit song “Dead Man’s Curve.” I thought about this song when I read the Conference of State Bank Supervisors’ (“CSBS”) Proposed Regulatory Prudential Standards...more

Mayer Brown

Treating a Nonbank Like a Bank: New Proposed Prudential Standards for Nonbank Mortgage Servicers

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Should US state nonbank mortgage servicers be subject to “safety and soundness” standards of the type imposed by federal law on insured depository institutions, even though the nonbanks do not solicit and hold customer funds...more

Morgan Lewis - All Things FinReg

OCC Issues Final ‘True Lender’ Rule

The Office of the Comptroller of the Currency (OCC) issued a final rule on October 27 that determines when a national bank or federal savings association (bank) makes a loan and is the “true lender” in the context of a...more

Ballard Spahr LLP

OCC issues proposed “true lender” rule

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Less than two months after issuing its final “Madden fix” rule, the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a...more

Robins Kaplan LLP

Your Daily Dose Of Financial News

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Last Friday, the White House asked the SEC to “consider eliminating requirements that publicly traded companies post quarterly earnings reports.” Such disclosures, however, are required by federal securities law, so they’re...more

Robins Kaplan LLP

Your Daily Dose of Financial News

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Europe’s much-ballyhooed (and feared) General Data Protection Regulation (“GDPR”) officially goes into effect today.  Here’s a look at the mad dash across all sectors (and outside of the EU) to comply....more

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