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Disclosure Requirements Borrowers

Troutman Pepper Locke

California Home Improvement and Solar Financing Bill Passed by Senate and Moving Through Assembly

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An initiative designed to add significant regulatory obligations to the home improvement and solar financing industries is progressing through the California legislature. Senate Bill 784 (SB 784) passed the California Senate...more

Goodwin

Connecticut Enacts Law Regulating Earned Wage Access Services

Goodwin on

Connecticut has enacted a law (the amendment) amending the state’s existing small loan act (the act). In this alert, we focus on the amendment’s application of the act to “earned but unpaid wage or salary income advances”...more

Hogan Lovells

UK Mortgage Rule Review: FCA discussion paper on future of market seeks views on ‘trade-offs and risks’ that changing its rules...

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Following the FCA’s May 2025 ‘first steps’ consultation on proposals to simplify its mortgage framework via a Mortgage Rule Review (MRR), it has now published a discussion paper on the future of the mortgage market. The...more

Sheppard Mullin Richter & Hampton LLP

Texas Passes Legislation to Regulate Sales-Based Financing

On June 20, Texas Governor Greg Abbot signed into law HB 700, adding Chapter 398 to the Texas Finance Code. Effective September 1, the statute establishes a regulatory framework for commercial sales-based financing and...more

Troutman Pepper Locke

Texas Enacts New Commercial Sales-Based Financing Bill Severely Restricting Automatic Debits

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On June 20, the Texas Legislature passed H.B. 700, which introduces several new regulatory requirements for providers and brokers of commercial sales-based financing operating within the state. The law applies to merchant...more

Hogan Lovells

UK consumer credit act reform: Phase 1 consultation update

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HM Treasury published its long-anticipated consultation on Phase 1 of the proposed reform of the Consumer Credit Act 1974 (CCA) on 19 May 2025. The consultation signals a significant move away from prescriptive legislation...more

McGlinchey Stafford

Court Finds No TILA Violation for Not Providing TILA Disclosures During Pre-Approval Process

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In a recent case, the United States District Court for the District of Connecticut granted a motion to dismiss, finding that the Defendant had no obligation to provide disclosures under the Truth in Lending Act (TILA) during...more

Alston & Bird

Missouri Enacts Commercial Financing Law

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What Happened? As we have previously apprised you, California, New York, Utah, Virginia, Georgia, Florida, Connecticut, and Kansas have enacted laws that require certain commercial financing “providers” to furnish certain...more

Alston & Bird

States Impose Commercial Financing Disclosure Requirements

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What Happened: In a little-noticed development, eight states have enacted legislation that requires specific disclosures for commercial non-real estate secured financing transactions....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

Lowenstein Sandler LLP

The SEC’s Private Fund Adviser Rules Explained — Part 1: The Restricted Activities Rule

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On August 23, 2023, the U.S. Securities and Exchange Commission (SEC) adopted new and amended rules under the Investment Advisers Act of 1940, as amended (the Advisers Act), to address what it perceives as certain conflicts...more

White & Case LLP

US SEC Adopts Final Private Fund Adviser Rules

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On August 23, 2023, the US Securities and Exchange Commission ("SEC") voted 3 – 2 to approve the adoption of significant new rules applicable to advisers of private funds (the "Private Fund Adviser Rules"). With these...more

Orrick, Herrington & Sutcliffe LLP

Connecticut joins states enacting commercial financing disclosures and lender and broker registration requirements

On June 28, Connecticut became the latest state to require certain providers of sales-based commercial financing to provide disclosures to borrowers and that such providers and brokers register with the state. SB 1032 (the...more

Proskauer Rose LLP

Green Loans – The FCA's Review of the Sustainability-Linked Loans Market

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Background On 29 June 2023, the UK’s Financial Conduct Authority (“FCA”) published a letter on the findings of its review of the sustainability-linked loans (“SLL”) market. SLLs aim to support sustainable economic activity...more

Bowditch & Dewey

[Webinar] Full Disclosure – Tips, Tricks and Traps for the Unwary in Navigating Public Finance Disclosure Obligations: Part II –...

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The newly-enacted Financial Data Transparency Act (FDTA) has the potential to significantly change the format currently used by issuers and conduit borrowers in submitting financial information to the Municipal Securities...more

Baker Donelson

Countdown Begins for Compliance with New York's Commercial Finance Disclosure Law as New York Issues Final Rule

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The New York State Department of Financial Services issued its final rule on February 1, 2023, implementing the state's new Commercial Finance Disclosure Law. Commercial financing providers that are subject to the law have a...more

Troutman Pepper Locke

New York Adopts Commercial Financing Transaction Disclosure Requirements

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On February 1, the Superintendent of Financial Services Adrienne A. Harris announced that the New York State Department of Financial Services completed the process for adopting a new regulation relating to disclosure...more

Walkers

End of Court Year Case Digest: Irish Insolvency & Restructuring Judgments

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As another Irish Court year will soon commence, now is an opportune time to look back at some of the more interesting insolvency and restructuring judgments to have been delivered in the Superior Courts during the last 12...more

Sheppard Mullin Richter & Hampton LLP

4th Circuit: Borrower Must Return Loan Proceeds After Rescission Despite Lender’s Failure to Meet TILA Requirements

Recently, the United States Court of Appeals for the 4th Circuit held that a mortgage servicer’s failure to provide a required disclosure informing borrowers of their three-day right to rescind the loan under the Truth in...more

Goodwin

SEC Proposes Short Sale Disclosure Rule and Reopens Comment Period for Reporting on Securities Loans

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed a new rule to increase market transparency regarding short selling and extended the comment period for its proposed rule requiring reporting on...more

Troutman Pepper Locke

Lenders Receive Additional Time to Comply With New York State Commercial Finance Disclosure Law

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On December 31, 2021, the New York Department of Financial Services (Department) announced that commercial finance providers doing business in New York state will receive additional time to comply with the New York State...more

Goodwin

FinCEN Proposes Rule for SARs Sharing Pilot Program

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In This Issue. The Financial Crimes Enforcement Network (FinCEN) issued a proposed rule about the establishment of a limited-duration pilot program for sharing suspicious activity reports (SARs); FinCEN published the final...more

Vinson & Elkins LLP

V&E’s Comprehensive Primer On Sustainable Finance

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The amount of money invested in Environmental, Social and Governance (ESG) funds has increased exponentially in the past year, and as banks and investors increasingly turn their attention to ESG factors, companies are also...more

Morrison & Foerster LLP

Sustainable Finance Disclosure Regulation (SFDR): What To Expect

As recently confirmed, the EU Sustainable Finance Disclosure Regulation (SFDR), becomes effective on 10 March 2021. The SFDR imposes sustainability-related disclosure requirements on financial services institutions such as...more

Schwabe, Williamson & Wyatt PC

Asking for Forgiveness: Revised PPP Loan Forgiveness Applications and Guidance

Forgiveness ‎Applications and the detailed instructions for the revised and updated applications posted on January 19, 2021, ‎as well as other forgiveness procedures as updated by the Economic Aid to Hard-Hit Small...more

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