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Regulation Z Regulatory Requirements Consumer Financial Products

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

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

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The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is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

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

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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

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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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