Consumer Finance Monitor Podcast Episode: How the CFPB Is Using Interpretive Rules to Expand Regulatory Requirements for Innovative Consumer Financial Products; Part Two: Earned Wage Access
Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule — Payments Pros – The Payments Law Podcast
Understanding the CFPB's Payday Loan Rule: Implications and Compliance — Payments Pros – The Payments Law Podcast
Understanding the CFPB's Payday Loan Rule: Implications and Compliance — The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: A Close Look at the Recent Study of the Effects of Illinois' 36% “All-In” Interest Rate Cap on Small-Dollar Credit Availability, with Special Guest Tom Miller
Fifth Circuit Rules that the Consumer Financial Protection Bureau is Unconstitutionally Funded: What Does the Decision Mean? A Deep Dive with Special Guest Isaac Boltansky, BTIG
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
Earned Wage Access (EWA) lets employees access wages they've already earned, but haven't yet been paid, typically through an app or digital service. For workers, this can mean avoiding payday loans or overdraft fees....more
New York Attorney General Letitia James has sued payday lenders MoneyLion Inc. and DailyPay Inc. in New York state court, alleging that the two companies took advantage of tens of thousands of New Yorkers....more
On March 28, the CFPB announced that it will not prioritize enforcement or supervision of the remaining provisions of its Payday, Vehicle Title, and Certain High-Cost Installment Loans Regulation, which were set to take...more
On March 28, the CFPB announced it would not prioritize enforcement or supervision actions related to penalties or fines associated with the payment withdrawal and payment disclosure provisions of the “Payday, Vehicle Title,...more
Just two days before its Payday, Vehicle Title, and Certain High-Cost Installment Loans final rule was slated to go into effect (and eight years after it was finalized), the Consumer Financial Protection Bureau (CFPB)...more
A proposed class action lawsuit has been filed in the U.S. District Court for the Northern District of California against EarnIn, a FinTech provider of Earned Wage Access services, alleging that its optional fees and tips...more
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
On July 26, 2023, the Consumer Financial Protection Bureau (CFPB) issued its Summer 2023 Supervisory Highlights describing key findings and violations identified during examinations conducted between July 2022 and March 2023....more
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
On January 24, the U.S. Court of Appeals for the Fourth Circuit concluded that a district court did not abuse its discretion when certifying a class action. The lawsuit alleges an individual who orchestrated an online payday...more
Notably, California has a constitutional limitation on interest rates (Cal. Const. Art. XV, Section 1). Section 25118 exempts certain evidences of indebtedness that meet specified conditions. One of these conditions is...more
During the past year, small-dollar lenders learned the fate of the Consumer Financial Protection Bureau’s (“CFPB”) final rulemaking addressing payday, vehicle title, and certain high-cost installment loans. In addition, the...more
Payday loans are small-dollar cash loans typically due in a single payment on the borrower’s next payday—they are extremely short-term and generally high-interest forms of consumer credit. If the borrower cannot pay off the...more
District Court Denies Payday Lender's Bid To Dismiss SEC Enforcement Action; Delaware Chancery Court Dismisses Camping World Insider Trading Derivative Suit; California Federal Judge Certifies Class Of Apple Common-Stock...more
[co-authors: Amelie Hopkins, and Collin Grier] The year 2021 started with the hope of COVID-19 vaccines and a return to (relative) normalcy, only to conclude with new variants that presented new challenges and extended...more
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
On March 22, the Consumer Financial Protection Bureau (Bureau) moved to dismiss a challenge to a final rule it promulgated last summer. But this routine filing was followed by a blog that expressed the Bureau’s intent to...more
On March 23, 2021, the CFPB issued a brief statement highlighting its position regarding “consumer harms in the small dollar lending market” and likely future action to reverse the previous CFPB administration’s policy...more
How Virginia’s 2020 Fairness in Lending Act Reforms Small-Dollar Loans - "The law closes regulatory loopholes, caps interest rates, and provides lessons for other states." Why this is important: Earlier this year, the...more
The impact of state usury laws on marketplace lending has been an area of concern since the inception of the industry. In a technique borrowed from the payday lending industry, online platforms that make unsecured consumer...more
In This Issue. The Federal Deposit Insurance Corporation (FDIC) published new procedures for federal deposit insurance applications from applicants that are not traditional community banks; federal banking regulators released...more
In Davis v. Oasis Legal Fin. Operating Co., LLC, 18-10526, 2019 WL 4051592 (11th Cir. Aug. 28, 2019), the U.S. Court of Appeals for the Eleventh Circuit (“Eleventh Circuit”) affirmed a decision in the U.S. District Court for...more
Welcome to the 2018 Year-End Report from BakerHostetler’s Financial Services Industry Team . We are pleased to share our analysis of some of the key developments in the financial services industry in 2018 and our expectations...more