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Disclosure Requirements Consumer Financial Products

Orrick, Herrington & Sutcliffe LLP

Massachusetts state court allows consumer protection suit over home equity investment product to proceed

On August 21, a Massachusetts superior court denied a motion to dismiss filed by a financial technology company offering a home equity investment (HEI) product. The financial technology company asserted that the HEI is an...more

Orrick, Herrington & Sutcliffe LLP

Illinois enacts two new consumer protection laws regulating digital assets

On August 18, Governor Pritzker of Illinois announced he had signed two comprehensive pieces of consumer protection legislation: The Digital Assets and Consumer Protection Act, which will regulate digital asset companies; and...more

Sheppard Mullin Richter & Hampton LLP

Illinois Proposes Regulations for Shared Appreciation Agreements Under the Residential Mortgage License Act

On August 15, the Illinois Department of Financial and Professional Regulation proposed regulations to implement recent amendments to the Residential Mortgage License Act of 1987 (RMLA) covering “shared appreciation...more

Troutman Pepper Locke

Illinois Amends Student Loan Servicing Rights Act to Include Educational Income Share Agreements

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On August 15, Illinois Governor JB Pritzker approved Public Act 104-0383. This legislation, effective immediately, amends the Student Loan Servicing Rights Act and introduces Article 7, focusing on Educational Income Share...more

Ballard Spahr LLP

Louisiana earned wage access law goes into effect

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An earned wage access (EWA) law has gone into effect in Louisiana. The legislation, passed earlier this year, became law without the signature of Gov. Jeff Landry....more

Ballard Spahr LLP

Regulatory Requirements Related to Adverse Action Notifications

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As part of the Federal Reserve Board’s Outlook Live Webinar series, on July 17, 2025, examiners from the Minneapolis and Chicago Federal Reserve Banks hosted a webinar to discuss the regulatory requirements related to adverse...more

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

Troutman Pepper Locke

From Banks to FinTech: The Evolution of Small Business Lending — The Consumer Finance Podcast

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In this special crossover edition of Payments Pros and The Consumer Finance Podcast, Carlin McCrory and Jason Cover are joined by their colleague Caleb Rosenberg to explore the evolving landscape of small business financing....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

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

Mayer Brown

North Dakota Broadens Licensing Law to Include Alternative Financing

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North Dakota recently enacted legislation that amends the state’s main non-mortgage lender licensing law, the North Dakota Money Brokers Act (the “Act”), to define a “loan” to include any “alternative financing product” that...more

Ballard Spahr LLP

New York Gov. Hochul signs legislation that includes BNPL Licensing Requirements and other Consumer Protection Provisions

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New York Gov. Kathy Hochul has signed legislation that, among other things, imposes new licensing requirements on Buy Now, Pay Later services....more

Troutman Pepper Locke

Welcoming a New Payment Pro: Jason Cover Joins the Payments Pros Podcast — Payments Pros – The Payments Law Podcast

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In this episode of Payments Pros, Carlin McCrory introduces Jason Cover as a new co-host. Jason, a partner in Troutman Pepper Locke's Consumer Financial Services practice, brings extensive knowledge in consumer lending and...more

Orrick, Herrington & Sutcliffe LLP

New York governor announces financial services updates for state

On May 9, New York Governor Kathy Hochul announced several updates related to financial services for the State of New York. Hochul announced new legislation as part of the FY26 enacted budget to regulate “Buy Now, Pay Later”...more

Sheppard Mullin Richter & Hampton LLP

Indiana Enacts Earned Wage Access Law 

On May 6, Indiana Governor Mike Braun signed House Enrolled Act No. 1125 into law, making Indiana the latest state to enact a statutory framework for regulating earned wage access (EWA) products. The Indiana Earned Wage...more

Goodwin

Indiana Enacts Law Regulating Earned Wage Access Services

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Indiana has enacted a law that establishes a financial-services oversight regime for earned wage access services, also known as on-demand pay services, which allow workers to access earned but unpaid income before payday....more

Troutman Pepper Locke

New Virginia Law Mandates Disclosure of Mandatory Fees in Consumer Transactions, Subject to Certain Exemptions

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On May 2, Virginia Governor Glenn Youngkin signed Senate Bill 1212 (SB 1212) into law, introducing new requirements and prohibitions under the Virginia Consumer Protection Act. Specifically, SB 1212 targets the disclosure of...more

Sheppard Mullin Richter & Hampton LLP

Texas Legislature Proposes Disclosure Rules for Commercial Financing 

The Texas House and Senate introduced House Bill 700 and Senate Bill 2677 to regulate commercial sales-based financing transactions. The proposed legislation would impose standardized disclosure requirements, require broker...more

A&O Shearman

FCA consults on further proposals to support Consumer Composite Investments regime

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The UK Financial Conduct Authority (FCA) has published a consultation paper together with a related press release and webpage setting out further proposals on product information for Consumer Composite Investments (CCIs). The...more

A&O Shearman

FCA findings on multi-firm review of trading apps

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The UK Financial Conduct Authority (FCA) has published a webpage summarising the findings from its multi-firm review of trading apps, together with a press release. The FCA notes that this is a growing sector allowing more...more

Mayer Brown

Arkansas and Utah Enact Laws to Regulate Earned Wage Access Providers

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Just days apart, Arkansas and Utah enacted laws to regulate providers of earned wage access (“EWA”) services, joining the handful of states that have enacted legislation to regulate these products since 2022. Arkansas House...more

Hudson Cook, LLP

What the Massachusetts "Junk Fee" Rules Mean for Automotive Sales and Marketing Efforts

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In early March, the Massachusetts Attorney General's Office finalized the commonwealth's regulations on unfair and deceptive fees, which it refers to in its press release as "junk fee" regulations, while simultaneously...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

Sheppard Mullin Richter & Hampton LLP

Utah and Arkansas Enact Earned Wage Access Regulations

Utah and Arkansas have enacted new legislation governing earned wage access (EWA) services, establishing state-level registration obligations and consumer protection standards. Both laws clarify that EWA services are not...more

Hogan Lovells

UK Consumer Duty rule review: FCA sets out ‘targeted steps’ to simplify requirements for firms

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Following feedback to its July 2024 Call for Input (CfI) on placing greater reliance on the Consumer Duty instead of specific rules and guidance, the FCA won’t be carrying out a wholesale Handbook review. It has instead...more

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