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Financial Regulatory Reform Disclosure Requirements Consumer Financial Products

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

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

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

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

Latham & Watkins LLP

FCA Publishes 5-Year Strategy and Outcome of Rule Review

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FCA outlines its priorities and areas in which it plans to reduce the regulatory burden for firms. On 25 March 2025, the FCA published its five-year strategy (Strategy), alongside the outcome of its review of retail conduct...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: How to Use the Restatement of Consumer Contracts - A Guide for Judges

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Today’s podcast show features a discussion with Professor Gregory Klass of Georgetown University Law School about an article he co-authored with Professor Ian Ayres, entitled “How to Use the Restatement of Consumer Contracts:...more

A&O Shearman

FCA statement on motor finance review next steps

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The UK Financial Conduct Authority (FCA) has published a statement informing firms, consumers and stakeholders of next steps in its review of the past use of motor finance discretionary commission arrangements. The Court...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

Troutman Pepper Locke

CFPB Proposes Amendments to Disclosure Requirements Under Remittance Transfer Rule

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On September 20, the Consumer Financial Protection Bureau (CFPB or Bureau) announced a proposed rule aimed at amending the disclosure requirements for international money transfers, commonly known as remittances. The proposed...more

Ballard Spahr LLP

CFPB proposes ‘narrow’ amendment to disclosure requirements for international remittances and money transfers

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The CFPB has issued a proposed rule with a small amendment to disclosure requirements for certain international remittances and money transfers....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

Connecticut Department of Banking issues guidance on consumer-like disclosures in sales-based financing offers

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On June 10, 2024, the Connecticut Department of Banking (“Department”) issued guidance (the “Guidance”) to give direction on required consumer-like disclosures in certain commercial financing offers....more

Troutman Pepper Locke

Kansas Becomes Fourth State to Enact Earned Wage Access Legislation

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On April 19, Kansas Governor Laura Kelly signed House Bill (HB) 2560 to regulate earned wage access (EWA) products and services. HB 2560 enacts the Earned Wage Access Services Act that requires EWA providers to be licensed by...more

Troutman Pepper Locke

Proposed Legislation in Louisiana Aims to Regulate Commercial Financing Transactions

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On March 1, Senate Bill (SB) 335 was introduced, which, if passed, would impose certain requirements on “commercial financing transactions.” Recently, multiple states have enacted disclosure regulations for commercial...more

Troutman Pepper Locke

New York Enacts Credit Card Surcharge Caps and Disclosure Requirements

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Last month, New York Governor Kathy Hochul signed into law Assembly Bill 2672, which both prohibits sellers from charging a credit card surcharge greater than what they are charged by the credit card company and requires...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

Troutman Pepper Locke

Connecticut Becomes Latest State to Enact a Commercial Financing Disclosure and Registration Law

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On June 28, Connecticut Governor Ned Lamont signed into law Senate Bill 1032 entitled An Act Requiring Certain Financing Disclosures, which requires certain providers of commercial financing to make various disclosures and...more

Troutman Pepper Locke

California AG Agrees with CFPB’s Preliminary Preemption Determination, Urges Bureau to Further Narrow TILA Preemption

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As discussed here, on December 7, 2022, the Consumer Financial Protection Bureau (CFPB or Bureau) made a preliminary conclusion that a New York commercial financing law was not preempted by the Truth in Lending Act (TILA)....more

Mayer Brown

Utah Enacts Commercial Financing Disclosure Law with a Registration Obligation

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Utah has followed California and New York by enacting its own Truth in Lending-like commercial financing disclosure law, but with an additional twist—Utah’s new law has a registration requirement. On March 24, Utah Governor...more

Orrick, Herrington & Sutcliffe LLP

ESG: Regolamento (UE) n. 2088/2019 relativo all’informativa sulla sostenibilità nel settore dei servizi finanziari

Il prossimo 10 marzo 2021 entreranno in applicazione alcune delle misure introdotte dal Regolamento (UE) n. 2019/2088 relativo all’informativa sulla sostenibilità nel settore dei servizi finanziari (il “Regolamento” o...more

Goodwin

SEC Adopts Broad Exempt Offering Reforms

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In the News. The Securities and Exchange Commission (SEC) adopted broad exempt offering reforms; the Department of Labor (DOL) finalized a rule, with significant revisions from the original proposal, on ESG investments; the...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

Mayer Brown

FDIC Adopts Changes to Securitization Safe Harbor Rule

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Since its adoption in 2010, the Federal Deposit Insurance Corporation’s (the “FDIC”) securitization safe harbor rule, 12 C.F.R. § 360.6 (the “Rule”), which relates to the treatment of financial assets transferred in...more

Ballard Spahr LLP

Georgia and Colorado Address MLO Temporary Authority to Operate

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Following receipt and consideration of three written comments on proposed rules distributed on November 18, 2019, the Georgia Department of Banking and Finance adopted final rules on December 20, 2019, that establish...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

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