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Consumer Financial Protection Bureau (CFPB) Regulatory Requirements Disclosure Requirements

Husch Blackwell LLP

Five Things to Know About the New York Buy-Now-Pay-Later Act

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As part of an omnibus 2026 budget bill, New York passed a new law that will broadly govern point-of-sale (POS) installment financing offered to New York residents. The Buy-Now-Pay-Later (BNPL) Act was signed into law in early...more

Venable LLP

Why Fintechs Can't Always Skip the State Licensing Maze for Earned Wage Access

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Earned Wage Access (EWA) lets employees access wages they've already earned, but haven't yet been paid, typically through an app or digital service. For workers, this can mean avoiding payday loans or overdraft fees....more

Sheppard Mullin Richter & Hampton LLP

CFPB Drops Lawsuit Against Lease-to-Own Fintech Following Adverse Credit Ruling

On May 27, the CFPB filed a notice of dismissal with prejudice in its lawsuit against a lease-to-own fintech provider. The lawsuit, filed in July 2023, alleged that the company’s rental-purchase agreements violated several...more

GeoDataVision

Why Does the CFPB Disguise Important Mortgage Data?

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Banks play a pivotal role in the economic wellbeing of our nation and local communities. Banks do this by being “financial intermediaries” facilitating the flow of funds between savers and borrowers. This obligation is so...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

Troutman Pepper Locke

California Introduces Its Version of the CARS Act Signaling a New Wave of State Regulation for Auto Dealers

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In a move that could significantly impact the auto retail industry, California has introduced Senate Bill 766, known as the California Combating Auto Retail Scams (CARS) Act. Introduced by Senator Benjamin Allen (D) on...more

Husch Blackwell LLP

Alternative Commercial Finance Monthly | January 2025

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As we step into a new year, we’re excited to introduce a fresh look for our Alternative Commercial Finance blog. Alongside a new monthly publication schedule, we’ll be placing a stronger emphasis on upcoming laws,...more

Orrick, Herrington & Sutcliffe LLP

CFPB files amicus brief on FCRA disclosure requirements

On January 16, the CFPB filed an amicus brief with the U.S. Court of Appeals for the Seventh Circuit, arguing that the FCRA disclosure requirements intended to allow consumers to correct inaccurate information applied to all...more

Foley & Lardner LLP

FTC Announces Final Junk Fees Rule Applying to Live-Event Tickets and Short-Term Lodging

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On December 17, 2024, the U.S. Federal Trade Commission (FTC) announced its final “Junk Fees Rule” (the “Final Rule” or “Rule”) to prevent certain practices related to pricing in the live-event ticketing and short-term...more

Jenner & Block

Client Alert: Buy Now, Pay Later: A Roadmap for Providers as Regulators Continue to Increase Scrutiny

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Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

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In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

Morgan Lewis - All Things FinReg

CFPB Outlines Small Business Lending Data Collection Rule Proposals

Section 1071 of the Dodd-Frank Act amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to compile, maintain, and submit to the Consumer Financial Protection Bureau (CFPB or Bureau) certain data...more

Ballard Spahr LLP

CFPB Publishes TRID FAQ’s on Treatment of Lender Credits

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The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more

Ballard Spahr LLP

CFPB issues proposed rule to require debt collectors to make disclosures for time-barred debts

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The CFPB has issued a proposal that would require debt collectors to make specified disclosures when collecting time-barred debts (Disclosure Proposal).  The Disclosure Proposal supplements the Bureau’s proposed debt...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

State AGs seek withdrawal or substantial modification of CFPB’s proposal to revise trial disclosure policy

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A group of 11 state attorneys general and the District of Columbia AG submitted a comment letter to the CFPB on its proposed revisions to its trial disclosure policy (TDP) in which they ask the Bureau to withdraw or...more

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