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Regulation Z Regulatory Requirements

Orrick, Herrington & Sutcliffe LLP

FDIC issues its 2025 Consumer Compliance Supervisory report

On July 3, the FDIC released its 2025 edition of its Consumer Compliance Supervisory Highlights report. The report described the FDIC’s aggregated findings from approximately 800 consumer compliance examinations conducted in...more

Troutman Pepper Locke

Troutman Pepper Locke Weekly Consumer Financial Services Newsletter – June 2025 # 2

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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

Morgan Lewis

CFPB Revokes Guidance in Sweeping Rollback of Agency Policies and Priorities

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In a sweeping announcement, the Consumer Financial Protection Bureau (CFPB) revoked nearly 70 interpretive rules, advisory opinions, and guidance documents on May 12, 2025. The Federal Register Notice adds to the pullback on...more

Orrick, Herrington & Sutcliffe LLP

CFPB states it will not enforce rule targeting Buy Now, Pay Later loans

On May 6, the CFPB announced it will not prioritize enforcement of its May 2024 interpretive rule which classified Buy Now, Pay Later providers as credit card issuers subject to TILA and Regulation Z (covered by InfoBytes...more

Sheppard Mullin Richter & Hampton LLP

CFPB Late Fee Rule Vacated by Texas Federal Court 

On April 15, Judge Mark T. Pittman of the U.S. District Court for the Northern District of Texas entered an Order and Final Judgement vacating the CFPB’s 2024 credit card late fee rule (previously discussed here) for...more

Brownstein Hyatt Farber Schreck

CFPB Drops Indirect Lending Case

On April 22, the Consumer Financial Protection Bureau (CFPB) requested the U.S. District Court for the Southern District of New York to remove the bureau as a plaintiff in CFPB v. Credit Acceptance Corporation, a case that...more

Orrick, Herrington & Sutcliffe LLP

CFPB gets its credit card late fee rule tossed

On April 15, the U.S. District Court for the Northern District of Texas vacated the CFPB’s Credit Card Late Fee Rule pursuant to a joint motion for entry of consent judgment reached by the parties. The court found the CFPB’s...more

Kilpatrick

CFPB Shifts Course on Buy Now, Pay Later: Interpretive Rule Revoked, Legal Challenge Implications

Kilpatrick on

The Consumer Financial Protection Bureau (CFPB) recently announced a significant change in its approach to the burgeoning "buy now, pay later" (BNPL) market. The Bureau has announced plans to revoke its May 2024 interpretive...more

Ballard Spahr LLP

CFPB plans to revoke BNPL interpretive rule

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The CFPB intends to revoke its Buy Now, Pay Later interpretive rule, according to a status report and joint motion to stay filed by the Bureau and the Financial Technology Association (FTA) in a case brought by the FTA...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks additional time to consider its position on “Buy Now, Pay Later” Interpretive Rule

On February 28, the U.S. District Court for the District of Columbia received a court filing from the CFPB and its Acting Director Russell Vought, indicating they intend to submit a status report by March 31 on whether the...more

Ballard Spahr LLP

CFPB revokes EWA advisory opinion

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The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is defined in the Truth in Lending Act and...more

Skadden, Arps, Slate, Meagher & Flom LLP

CFPB Releases Final ‘Open Banking’ Rule on Personal Financial Data Rights

On October 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a final rule (Rule) on personal financial data rights under Section 1033 of the Dodd-Frank Act. The Rule imposes significant new obligations on...more

Troutman Pepper Locke

Finding the Balance: Complying with Consumer Finance Legal Obligations When Offering Patient Payment Plans

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Health care providers often find themselves in the position of collecting direct payments for medical services through patient payment plans. While providers must adhere to a myriad of health care laws when doing so, they...more

Jenner & Block

Client Alert: Buy Now, Pay Later: A Roadmap for Providers as Regulators Continue to Increase Scrutiny

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Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more

Jenner & Block

Client Alert: Navigating the EWA Regulatory Landscape

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I. Introduction: EWA on the Precipice - The increasing use of earned wage access (“EWA”) by workers in the United States and around the world has helped to bring financial flexibility to many previously constrained by the...more

Ballard Spahr LLP

CFPB partners with State of Maine in amicus brief on Truth in Lending Act coverage

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The CFPB has filed an amicus brief jointly with Maine’s Attorney General, Bureau of Financial Institutions, and Bureau of Consumer Credit Protection in the Maine Supreme Judicial Court in a case, Franklin Savings Bank v....more

Cadwalader, Wickersham & Taft LLP

CFPB Amicus Brief Emphasizes Strength of Truth In Lending Act Anti-Evasion Precedent

The Consumer Financial Protection Bureau ("CFPB") filed an amicus brief in Franklin Savings Bank v. Bordick, a case before the Supreme Court of Maine. In that case, the borrowers took out a loan that they used to finance...more

Goodwin

OCC Proposes Rules for CRA Benchmarks and Fair Access

Goodwin on

In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more

Akerman LLP

CFPB Issues Statement on Flexible Approach to Electronic Credit Card Disclosures

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On June 3, 2020, the Consumer Financial Protection Bureau (CFPB) issued a statement announcing temporary supervisory and enforcement flexibility during the COVID-19 pandemic for credit card issuers regarding electronic...more

Ballard Spahr LLP

CFPB Issues Statement On Electronic Credit Card Disclosures In Light Of COVID-19 Pandemic

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The CFPB has issued a statement regarding its supervisory and enforcement practices in connection with the electronic provision of certain credit card disclosures during the pandemic that are required by Regulation Z to be...more

Ballard Spahr LLP

CFPB Publishes TRID FAQ’s on Treatment of Lender Credits

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The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more

Ballard Spahr LLP

CFPB Publishes TRID Guides on Construction Loans

Ballard Spahr LLP on

Although the 2017 amendments to the TRID rule, often referred to as TRID 2.0, added commentary to TRID provisions of Regulation Z and, particularly, Appendix D to Regulation Z, that addresses multiple advance construction...more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments

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The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

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