News & Analysis as of

Non-Bank Lenders Disclosure Requirements

Skadden, Arps, Slate, Meagher & Flom LLP

FCA’s Approach to Non-Bank Leverage and Implications for Market Participants

On 25 February 2025, Sarah Pritchard, executive director of consumers, competition, and international at the UK Financial Conduct Authority (FCA), delivered a speech at the Investment Association Roundtable where she outlined...more

Husch Blackwell LLP

Missouri Enacts New Commercial Finance Disclosure Law

Husch Blackwell LLP on

Missouri is now part of the growing list of states who have introduced commercial finance disclosure requirements. Additionally, the statute – Section 427.300 of Missouri Senate Bill 1359 – contains substantial requirements,...more

Hudson Cook, LLP

[Webinar] Preparing for the New CFPB Enforcement Order Registry - June 27th, 2:00 pm ET

Hudson Cook, LLP on

Nonbank financial services companies with prior enforcement orders are preparing for the Consumer Financial Protection Bureau’s (CFPB) new Registry, which takes effect September 16. Nonbank consumer lenders, loan servicers,...more

Epstein Becker & Green

The FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Disclose Certain Security and Data Breaches

Epstein Becker & Green on

On October 27, 2023, the Federal Trade Commission (“FTC”) approved an amendment to the Safeguards Rule that requires non-banking financial institutions (e.g., mortgage companies, mortgage brokers, and creditors) to notify the...more

McGlinchey Stafford

Decoding State Commercial Financing Disclosure Laws, Floorplan Financing

McGlinchey Stafford on

Floorplan financing exemptions in the new state commercial financing disclosure laws may not be as broad as lenders think. Following in the footsteps of California in 2018, states across the nation — including Utah,...more

Paul Hastings LLP

Finance Providers Need to Be Aware of New Commercial Finance Disclosure Laws

Paul Hastings LLP on

While consumer lenders have long been attuned to disclosure requirements under the Truth in Lending Act, many commercial financiers are or soon will be subject to similar state-level obligations. On June 23, 2023, Florida...more

Seward & Kissel LLP

Proposed FDIC Rule Would Impose Additional Deposit Insurance Disclosure Obligations on Banks and Non-Banks

Seward & Kissel LLP on

The Federal Deposit Insurance Corporation (“FDIC”) published for comment in December 2022 a notice of proposed rulemaking (12 CFR Part 328) (“Proposed Rule”) that would apply to all FDIC-insured institutions and impose new...more

BCLP

Deceptive and Unfair - Multiple NSF Fees on Representments of the Same Transaction

BCLP on

In guidance issued recently, the Federal Deposit Insurance Corporation (“FDIC”) advised that charging multiple non-sufficient funds (“NSF”) fees constitute “violations of law” when customer disclosures do not fully and...more

Pillsbury Winthrop Shaw Pittman LLP

New York Enacts Novel Disclosure Requirements for Commercial Financing Transactions

Fintechs and other nonbanks will be required to provide consumer-style disclosures when offering to extend small business financing in New York. In late December 2020, New York Governor Andrew Cuomo signed into law...more

Robins Kaplan LLP

Your Daily Dose Of Financial News

Robins Kaplan LLP on

Last Friday, the White House asked the SEC to “consider eliminating requirements that publicly traded companies post quarterly earnings reports.” Such disclosures, however, are required by federal securities law, so they’re...more

Ballard Spahr LLP

House Financial Services Committee Schedules Oct. 11 Mark-Up of "Madden fix" Bill

Ballard Spahr LLP on

Among the more than 20 bills that the House Financial Services Committee was scheduled to mark up Wednesday, October 11, was a bill to provide a "Madden fix" as well as several others relevant to consumer financial services...more

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