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Consumer Financial Products › True Lender › Regulatory Agenda

Mayer Brown

What to Expect in Licensing in 2025

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With the currently revolving door of directors at the federal Consumer Financial Protection Bureau (CFPB)—which may soon be on its fourth director in 2025 alone—and an order issued by Acting CFPB Director Russell Vought to...more

Ballard Spahr LLP

Washington state “true lender” law signed, effective June 6, 2024

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After its passage by the Washington state legislature, Substitute Senate Bill (SSB) 6025, the Washington “predatory loan prevention act”, was approved by Governor Jay Inslee on March 25, 2024, with an effective date of June...more

Ballard Spahr LLP

“True Lender Act” Bill Proposed in Maryland

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Maryland has joined the ranks of states considering legislation that would codify elements of “true lender” theory in an effort to impose federally preempted state licensing requirements and rate caps on loans to Maryland...more

Troutman Pepper Locke

Washington D.C. Introduces Legislation Attacking Fintech-Bank Partnership Lending by Opting Out of DIDMCA and Codifying a “True...

Troutman Pepper Locke on

Late last month, Councilmember Kenyan R. McDuffie introduced B 25-0609, entitled the Protecting Affordable Loans Amendment Act of 2023, that proposes to opt the District of Columbia out of sections 521-523 of the Depository...more

Ballard Spahr LLP

Rate Exportation Opt-Out and “Anti-Evasion” Bill Introduced in Washington D.C.

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District of Columbia Council Bill B 25-0609, which would opt out of Section 27 of the Federal Deposit Insurance Act (“FDIA”) with respect to loans made in the District of Columbia, was introduced in the District of Columbia...more

Troutman Pepper Locke

Washington State Representatives Propose Amendments Targeting Bank Model Lending and Loan Programs Based on Tips or Memberships

Troutman Pepper Locke on

Washington now joins the list of states that have enacted or proposed legislation adopting so-called anti-evasion provisions, including legislation passed in Minnesota, Connecticut, Nebraska, and proposed in Florida. On...more

Ballard Spahr LLP

Predatory Loan Prevention Bill Introduced in Florida to Codify “True Lender” Analysis

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Florida SB 146, a bill that would add a “Predatory loan prevention” section to the Florida Consumer Finance Act has been introduced in the Florida Senate, seeking to curb bank-model lending programs and codify a “true lender”...more

Ballard Spahr LLP

Connecticut Issues Guidance Clarifying the Applicability of its Small Loan Act to “True Lenders” and Earned Wage Access Providers

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The Connecticut Department of Banking (the “Department”) issued a guidance letter on September 11, 2023 (the “Guidance”) providing its position regarding the amendments to Connecticut’s Small Loan Lending and Related...more

Morgan Lewis - All Things FinReg

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

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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

Ballard Spahr LLP

Treasury Recommends Sweeping Regulatory Changes for Consumer Financial Services

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A report issued last week by the U.S. Treasury Department recommends sweeping regulatory changes intended to promote innovation in the consumer financial services market, reduce regulatory burdens on consumer financial...more

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