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Payday Loans Financial Institutions

Husch Blackwell LLP

CFPB Floats Rescission of NBR Rule

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The Consumer Financial Protection Bureau (CFPB) continues to redefine its priorities, and among the many policies targeted for change, the “Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders”...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2025

The Federal Reserve has announced multiple decisions to rescind existing requirements for crypto-asset activities. The April 24 announcement included the rescission of a 2022 supervisory letter that required state member...more

Hudson Cook, LLP

CFPB Bites of the Month - April 2025 - "I'll Remember April and the CFPB"

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In this month's article, we share some of our top "bites" covered during the April 2025 webinar....more

Sheppard Mullin Richter & Hampton LLP

CFPB Publishes Supervisory Highlights Focused on Deposits, Small-Dollar Lending, BNPL, and Paycheck Advance Products

During the week of January 6, the CFPB released a “second” Winter 2024 Supervisory Highlights, focused on the agency’s most recent findings in deposits, small dollar lending, buy now, pay later (BNPL), paycheck advance...more

Husch Blackwell LLP

Mark Your Calendars: 2025 Compliance Dates for Key Consumer and Small Business Financial Services Regulations

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One of the primary challenges with working in the U.S. financial services space is keeping up with the ever-changing federal and state regulatory landscape. Juggling the day-to-day fire drills while staying atop of regulatory...more

Troutman Pepper Locke

CFSA Seeks Clarification from Fifth Circuit of Required Compliance Date for CFPB Payday Loan Rule

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On November 18, the plaintiff trade groups in Community Financial Services Association of America, Ltd.(CFSA) v. Consumer Financial Protection Bureau (CFPB) filed an Opposed Motion for Clarification of Stay Pending Appeal...more

Troutman Pepper Locke

CFPB’s Latest FAQs Broaden Interpretive Rule for Pay-in-Four BNPL Products

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On September 18, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a set of frequently asked questions (FAQs) providing guidance on applying Regulation Z requirements to Pay-in-Four Buy Now, Pay Later (BNPL)...more

Ballard Spahr LLP

CFPB: Payday Plaintiffs Not Entitled to En Banc Rehearing

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The plaintiffs challenging the CFPB payday lending rule should not be entitled to an en banc rehearing because the issues they cite already have become final and the time for rehearing has lapsed, the CFPB said last week...more

Nelson Mullins Riley & Scarborough LLP

Who is Paying Who: The Employee or the Employer?

Since 2022, the Consumer Financial Protection Bureau (CFPB) has a stated priority of “protecting employees and their rights through conducting reports, inquiries, and issuing requirements for employers.” In July 2024, the...more

Ballard Spahr LLP

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

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On July 18, 2024, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) proposed an interpretive rule that states (1) EWA products fall under the definition of “credit” under the Truth in Lending Act (“TILA”) and...more

Troutman Pepper Locke

CFPB Says Earned Wage Access Products are Subject to the Truth in Lending Act

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Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - June 2024 # 3

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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

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

South Carolina Enacts Earned Wage Access Legislation Requiring Registration, Exempting the Product from Lending Laws

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On May 21, 2024, South Carolina Governor Henry McMaster signed into law the Earned Wage Access Services Act (the “Act”), which will require earned wage access (“EWA”) providers to register annually with the state’s Department...more

Troutman Pepper Locke

Kansas Governor Enacts Significant Changes to Kansas Mortgage Business Act and Uniform Consumer Credit Code

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Kansas Governor Laura Kelly signed House Bill (HB) 2247 into law, bringing significant changes to the Kansas Mortgage Business Act and the Uniform Consumer Credit Code (UCCC). The changes brought about by HB 2247 will largely...more

Troutman Pepper Locke

California DFPI’s Proposed EWA Legislation Rejected by Office of Administrative Law

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As discussed here, in March 2023, the California Department of Financial Protection and Innovation (DFPI) proposed new regulations under the California Financing Law that would interpret the definition of “loan” to include...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

Wisconsin Legislature Passes Earned Wage Access Bill

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On February 20, the Wisconsin Senate passed House Bill (HB) 574 to regulate earned wage access (EWA) products and services. HB 574 creates a new chapter to the Wisconsin Statutes that requires EWA providers to be licensed by...more

Goodwin

2023 Year in Review: Payday and Small-Dollar Lending

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Welcome to the Payday and Small-Dollar Lending chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - Regulators may take additional regulatory and enforcement action...more

Shipkevich PLLC

Money Transmission Legislative & Regulatory Update: Minnesota, Nevada, Georgia, and Texas

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Minnesota - On May 24, 2023, the governor of Minnesota signed SF 2744, bringing amendments to various state statutes related to financial institutions. The amendments address the regulation and licensing of money...more

Wiley Rein LLP

Wiley Consumer Protection Download (January 24, 2022)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Ballard Spahr LLP

CFPB Fall 2021 Supervisory Highlights Look at Credit Cards, Debt Collection, Deposits, Fair Lending, Mortgage Servicing, Payday...

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The CFPB has released the Fall 2021 edition of its Supervisory Highlights. The report discusses the Bureau’s examinations in the areas of credit card account management, debt collection, deposits, fair lending, mortgage...more

Ballard Spahr LLP

CFPB Summer 2021 Supervisory Highlights looks at auto servicing, consumer reporting, debt collection, deposits, fair lending,...

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The CFPB has released the Summer 2021 edition of its Supervisory Highlights. The report, which contains 48 pages of supervisory observations, discusses the Bureau’s examinations in the areas of auto servicing, consumer...more

Spilman Thomas & Battle, PLLC

All Consuming - Financial Litigation Insights, Volume 2, Issue 11

A New Bill Could Allow Digital Closings Nationwide "Dubbed the SECURE Notarization Act, the bill would allow for remote online notarization services nationwide." Why this is important: In the wake of the coronavirus...more

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights, Issue 3

House Passes Cannabis Banking Bill - "The House passed the same bill in 2019 by a similar margin, but it stalled in what was then the GOP-controlled Senate." Why this is important: The Safe Banking Act, if passed, will...more

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