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Disclosure Requirements Financial Services Industry Regulation Z

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

Orrick, Herrington & Sutcliffe LLP

CFPB publishes CARD Act-mandated request for information

On January 17, the CFPB published in the Federal Register a Request for Information (RFI) about a number of aspects of the consumer credit card market, as mandated by the CARD Act. The RFI seeks public input to shape the...more

Troutman Pepper Locke

New Year = New Earned Wage Access Legislation in New York

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This week, New York became the latest state to introduce legislation aimed at regulating Earned Wage Access (EWA) services. Assembly Bill 258 titled — “An Act to Amend the Banking Law, in Relation to Providing for Income...more

Morrison & Foerster LLP

Leaning In: The CFPB Publishes Rule on Fees for Overdraft Services

On December 30, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that may dramatically change the way that certain large financial institutions offer overdraft services to consumers. Under the...more

Venable LLP

CFPB Issues FAQs: Expands Interpretive Rule for BNPL Products

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On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - September 2024 #4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week....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

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

Ballard Spahr LLP

CFPB proposed rule would makes certain overdraft program’s credit subject to Regulation Z disclosure requirements and could cap...

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In furtherance of the Biden Administration’s “junk fee” agenda, on January 17, 2024, the Consumer Financial Protection Bureau issued its proposed rule to amend Regulations E and Z to regulate overdraft services provided by...more

Orrick, Herrington & Sutcliffe LLP

3rd Circuit: Card renewal notices not subject to TILA itemization requirements

On April 11, the U.S. Court of Appeals for the Third Circuit upheld the dismissal of a putative class action suit claiming a national bank’s failure to itemize fees in its credit card renewal notices violated TILA and...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

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

April 1 effective date of prepaid rule leaves little remaining time for addressing significant compliance challenges

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After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019. ...more

Ballard Spahr LLP

CFPB updates TRID Rule small entity compliance guide

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The CFPB recently released a revised version of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October...more

Bradley Arant Boult Cummings LLP

The Prepaid Rule is Finally Here

Last week, the CFPB issued its long-awaited final rule amending Regulation E (Electronic Funds Transfer Act) and Regulation Z (Truth in Lending Act) to create regulations for prepaid financial products (Prepaid Rule). The...more

Ballard Spahr LLP

CFPB finalizes sweeping expansion of prepaid account regulations

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The CFPB has issued its long-anticipated final rule for general purpose prepaid accounts.  As expected, the new regulations expand the products covered by Regulation E, introduce significant new disclosure requirements,...more

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