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Interest Rates Financial Regulatory Reform

Troutman Pepper Locke

Understanding New York’s New Buy-Now-Pay-Later Law

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New York has included a “Buy-Now-Pay-Later Act” as part of its broader budget legislation for the 2025-2026 fiscal year. Encapsulated in Article 14-B, the Act aims to regulate the burgeoning market of buy-now-pay-later (BNPL)...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

Blake, Cassels & Graydon LLP

The Shape of Things to Come: Regulatory Developments in Canadian Payments 2025

Regulatory updates to Canada’s payments ecosystem are reshaping operational risk, compliance obligations and commercial terms across the sector. From interest rate thresholds to anti-money laundering safeguards, there are...more

Skadden, Arps, Slate, Meagher & Flom LLP

Servicemember Financial Protections Emerge as a Trump Enforcement Priority

Key Points - - The CFPB and DOJ have recently prioritized enforcement of federal servicemember protections. - The Servicemembers Civil Relief Act and Military Lending Act provide key protections such as interest rate caps,...more

Cadwalader, Wickersham & Taft LLP

U.S. Banks Quarterly Survey - April 2025

LEVEL-SETTING - The banking industry finds itself in the early stages of a transformation. Existing balance sheets have been shaped by more than a decade of low interest rates that fueled asset appreciation, muted...more

ArentFox Schiff

The End of LIBOR: Hotel California Edition [Part III]

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During the London InterBank Offered Rate (LIBOR) transition, and post LIBOR’s end date of June 30, 2023, the goal for all should be that (1) the effective interest rates be generally economically equivalent as a result of the...more

Ballard Spahr LLP

Oregon Considering DIDMCA Opt-Out Legislation

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Oregon may become the latest state attempting to stop out-of-state banks from “exporting” home-state interest rates on loans made to Oregon consumers. Like similar legislation adopted by Colorado in 2023, House Bill 2561...more

Orrick, Herrington & Sutcliffe LLP

Fed’s Bowman emphasizes a cautious monetary policy and regulatory reform for community banks

On February 17, Fed Governor Michelle Bowman delivered prepared remarks, during a conference in Arizona, addressing monetary policy, the economic outlook, and regulatory issues affecting community banks. She discussed the...more

Orrick, Herrington & Sutcliffe LLP

CRS examines Fed responsibilities and challenges in the 119th Congress

Recently, the Congressional Research Service published a report titled, “Federal Reserve: Policy Issues in the 119th Congress,” which analyzed policy issues for Congress in each category of the Fed’s responsibilities. The...more

Orrick, Herrington & Sutcliffe LLP

CFPB will reportedly continue to update Average Prime Offer Rate tables

On February 11, it was reported that, despite the temporary halt in the CFPB’s operations, the Bureau’s tables for the Average Prime Offer Rate (APOR) will continue to be updated weekly by the CFPB. A Bureau spokesperson...more

Ballard Spahr LLP

Senators Sanders, Hawley introduce legislation to cap credit card interest rates at 10%

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Sens. Bernie Sanders, I-Vt. and Josh Hawley, R-Mo. have introduced bipartisan legislation that could cap credit card interest rates at 10%....more

Orrick, Herrington & Sutcliffe LLP

Fed Member Bowman discusses challenges to mutual and community banks

On January 31, Fed Member Michelle Bowman addressed challenges faced by mutual banks and community banks at a New England CEO summit. Bowman provided a brief update on the state of the U.S. economy, including the rate of...more

ArentFox Schiff

The End of LIBOR: Hotel California Edition [Part II]

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On October 1, 2024, the United Kingdom Financial Conduct Authority (UK FCA) phased out ‘Zombie’ LIBOR, as a transitional benchmark, with the move to alternative “risk-free” rates....more

Troutman Pepper Locke

Senators Sanders and Hawley Propose Legislation Capping Credit Card Interest Rates

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On February 4, Senators Bernie Sanders (I-Vt.) and Josh Hawley (R-Mo.) introduced bipartisan legislation aimed at immediately capping credit card interest rates at 10% for a period of five years. This initiative follows a...more

Troutman Pepper Locke

Alaska Proposes Amendments to Small Loan Act Targeting Banking-as-a-Service Programs

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On January 10, the Alaska Legislature introduced Senate Bill 39 that aims to amend the state’s Small Loan Act. This proposed legislation seeks to implement significant changes, including the introduction of a predominant...more

Troutman Pepper Locke

Troutman Represents all Fifty States Bankers Associations and D.C. in Tenth Circuit DIDMCA Opt-Out Litigation

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In the last two weeks, several amicus briefs were filed in the Tenth Circuit in the ongoing litigation concerning Colorado’s opt-out from the Depository Institutions Deregulation and Monetary Control Act (DIDMCA). Troutman...more

Troutman Pepper Locke

States Join Colorado in Defense of Interest Rate Opt-Out Law

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On September 20, 13 states and Washington, D.C. joined Colorado in its appeal asking the Tenth Circuit to uphold a state law imposing more restrictive interest rate caps on loans from out-of-state banks to residents, arguing...more

Proskauer - Regulatory & Compliance

Motor Finance Complaints – An Update on the FCA’s Recent Activity

On 30 July 2024, the United Kingdom Financial Conduct Authority (“FCA”) published a number of updates in relation to its work on complaints against motor finance firms. In particular, the FCA published an update...more

Sheppard Mullin Richter & Hampton LLP

New Florida Law Overhauls Consumer Finance Loan Interest Rate Requirements

Florida recently enacted H1347, revising the state’s criteria for what constitutes usurious consumer loans. The Florida Consumer Finance Act prohibits charging an interest rate of more than 18% per year on a loan of...more

Ballard Spahr LLP

Colorado provides some (but not enough) guidance on new general-purpose credit card carve-out

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In the same 2023 bill (House Bill 23-1229) that included Colorado’s DIDMCA opt-out**, Colorado adopted a statute excepting certain “general-purpose credit cards”, as defined, from the state’s limitations on finance charges...more

Ballard Spahr LLP

VA Proposes Rules for ARM Loans and Temporary Buydown Agreements

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The U.S. Department of Veterans Affairs (VA) recently proposed rules under its home loan guaranty program regarding adjustable rate mortgage (ARM) loans, hybrid ARM (h-ARM) loans and temporary buydown agreements. Comments are...more

Troutman Pepper Locke

CFPB Announces “Payday Loan” Rule to Take Effect Next Year

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Last Week, the Consumer Financial Protection Bureau (CFPB) announced that its so-called “Payday, Vehicle Title and Certain High-Cost Installment Loans” rule (Rule) will go into effect on March 30, 2025. While ostensibly aimed...more

Ballard Spahr LLP

Oh, won’t you stay (enforcement): Plaintiffs seek preliminary injunction in Colorado interest rate preemption opt-out challenge

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Colorado’s attempt to opt out of interest rate exportation by out-of-state, state-chartered banks ultimately will fail, and will cause irreparable harm in the interim: therefore, enforcement of the opt out should be...more

Ballard Spahr LLP

Opt-out challenge case assigned to Colorado federal Judge Daniel D. Domenico

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As we previously reported, on March 25, 2024, three consumer financial services industry trade groups filed a lawsuit in federal district court in Colorado challenging legislation recently adopted to opt out of rate...more

Troutman Pepper Locke

Trade Organizations Challenge Colorado’s DIDMCA Opt-Out Legislation in Federal Court

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Monday, three trade organizations filed a complaint in Colorado federal court challenging H.B. 1229, Colorado’s effort to limit interest charges by out-of-state financial institutions, which is set to take effect on July 1,...more

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