News & Analysis as of

Exemptions Consumer Financial Products

Troutman Pepper Locke

Federal Agencies Issue Order Granting Exemption for Financial Institutions on TIN Collection

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The Office of the Comptroller of the Currency (OCC), alongside the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA) (collectively, the agencies), with concurrence from the...more

Ballard Spahr LLP

CFPB Adjusts HMDA Asset Exemption Threshold

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The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA)....more

Troutman Pepper Locke

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

Troutman Pepper Locke on

On October 4, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2025 are...more

Troutman Pepper Locke

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

Troutman Pepper Locke on

On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more

Hudson Cook, LLP

Fourth Circuit Takes Expansive View of MLA Auto-Loan Exemption

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In a decision highly anticipated by the auto finance industry, a federal appeals court recently held that auto loans remain exempt from the Military Lending Act even when they finance related costs or services beyond the...more

Goodwin

CFPB Launches New Initiative Focused on Rural Communities

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In This Issue. The Consumer Financial Protection Bureau (CFPB) announced a new initiative focused on financial issues faced by rural communities and also updated its examination procedures to cover unfair discrimination; the...more

Miles & Stockbridge P.C.

Certain Exemptions of the New California Consumer Financial Protection Law Need To Be Clarified

In our Legislative Alert of October 13, 2020, we reported on the California legislation enacted in late September, Assembly Bill 1864, that created the new California Consumer Financial Protection Law (“CCFPL”), and we set...more

Hinshaw & Culbertson - Consumer Crossroads

Massachusetts Attorney General Implements Emergency Debt Collection Regulations in Response to COVID-19 Crisis

From March 27 through June 25, 2020—or until the end of Massachusetts' state of emergency—Attorney General Maura Healey has implemented temporary regulations on the collection of debt from Massachusetts consumers, which...more

Ballard Spahr LLP

Alaska Exempts Nonprofit Organizations From Mortgage Lender Licensing Requirements

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The Alaska Department of Commerce, Community, and Economic Development recently adopted amendments to its mortgage lending regulations to exempt bona fide nonprofit organizations from the licensing requirement....more

Ballard Spahr LLP

Alaska Expands Mortgage Licensing Exemptions

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As a result of a new Alaska law, HB 104, the following are exempted from mortgage loan originator requirements in the state: Employees of federal, state, or local government agencies...more

Ballard Spahr LLP

Minnesota Revises Licensing Requirements Effective August 1, 2019

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Minnesota has revised its Residential Mortgage Originator and Servicer Licensing Act to provide an exemption from residential mortgage originator licensure requirements for a "manufactured home dealer" and "manufactured home...more

Ballard Spahr LLP

CFPB Publishes 2019 Final Lists of 'Rural' and 'Rural or Underserved' Counties

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The CFPB has published its 2019 final lists of "rural" and "rural or underserved" counties on its website. The CFPB has previously posted lists of such counties for calendar years 2011-2018....more

Ballard Spahr LLP

Vermont exempts bank partners from loan solicitation license for commercial loans

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We have been following closely efforts by state regulators, state legislatures and the courts to restrict, or in some cases prohibit, bank model lending programs, so the recent guidance from the Vermont Department of...more

Ballard Spahr LLP

Banking Regulators Issue Exemption from CIP Requirements for Premium Finance Loans

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The Federal Banking Agencies (“FBAs”) — collectively the Office of the Comptroller of the Currency (“OCC”); the Board of Governors of the Federal Reserve System (“Federal Reserve”); the Federal Deposit Insurance Corporation...more

Ballard Spahr LLP

CFPB proposes revisions to trial disclosure policy

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The CFPB is proposing significant revisions to its “Policy to Encourage Trial Disclosure Programs” (TDP Policy), which sets forth the Bureau’s standards and procedures for exempting individual companies, on a case-by-case...more

Ballard Spahr LLP

CFPB Provides Additional Guidance on HMDA Partial Exemption

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The CFPB recently released an interpretive and procedural rule to implement and clarify the partial exemption from the Home Mortgage Disclosure Act (HMDA) adopted in the Economic Growth, Regulatory Relief, and Consumer...more

Vedder Price

BSA/AML ALERT: FinCEN Grants a 90-Day Exemption from the Beneficial Ownership Rule for Certain Financial Product Renewals and...

Vedder Price on

On May 11, 2018, compliance with the beneficial ownership rule became mandatory. In accordance with the rule, a covered financial institution must verify, at the time a new account is opened, the beneficial owners opening the...more

Balch & Bingham LLP

That’s No Autodialer: D.C. Circuit Unwinds 2015 FCC TCPA Ruling

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This article addresses the Court’s reversal of over a decade of confusion regarding autodialers. The TCPA defines an autodialer (automatic telephone dialing system, or ATDS) as “equipment which has the capacity (a) to store...more

Balch & Bingham LLP

Revoking Contractual Consent is Different: D.C. Circuit Unwinds 2015 FCC TCPA Ruling

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Here, we address one significant component of the decision: the D.C. Circuit’s confirmation that consumers may revoke consent to call by any reasonable means but with the qualification that parties may be able to contract...more

Balch & Bingham LLP

No Safe Harbor for Reassigned Numbers: D.C. Circuit Unwinds 2015 FCC TCPA Ruling

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Here, we examine the D.C. Circuit’s reversal of not simply the one-call safe harbor for reassigned numbers imposed by the FCC’s 2015 TCPA ruling but also the Commission’s treatment of reassigned numbers as a whole. ...more

Balch & Bingham LLP

D.C. Circuit Unwinds 2015 FCC TCPA Ruling: An Overview

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In a watershed case, the United States Court of Appeals for the District of Columbia Circuit (D.C. Circuit) unwound key components of the controversial 2015 ruling by the Federal Communications Commission (FCC or Commission)...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2018 through...more

Ballard Spahr LLP

Director Cordray Responds To Letter from Senators Seeking Tailored Rulemaking for Community Banks and Credit Unions

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Last month, a bipartisan group of 70 senators were signatories to a letter sent to Consumer Financial Protection Bureau (CFPB) Director Richard Cordray urging the CFPB to “carefully tailor its regulations to match the unique...more

Ballard Spahr LLP

CFPB makes no change to exemption thresholds for appraisal requirement, Regs Z and M

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The CFPB has published notices in the Federal Register announcing that it is making no change to three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2016 through December 31,...more

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