Recently, the Ohio Department of Commerce issued an alert that nonbank entities receiving compensation for arranging or brokering bank loans of $5,000 or less must obtain a license under the Small Loan Act (SLA). This...more
As discussed here, on June 29, Connecticut Governor Ned Lamont signed SB 1033, An Act Concerning Various Revisions to the Banking Statutes, into law. Among other things, the bill: (1) raised the small loan limit from $15,000...more
The Connecticut Department of Banking (the “Department”) issued a guidance letter on September 11, 2023 (the “Guidance”) providing its position regarding the amendments to Connecticut’s Small Loan Lending and Related...more
Minnesota recently enacted the Commerce Omnibus Finance Bill, which includes amendments to several provisions of Minnesota law related to consumer loans and financial institutions....more
On June 29, Connecticut Governor Ned Lamont signed SB 1033, An Act Concerning Various Revisions to the Banking Statutes, into law. As discussed here, with this bill, Connecticut joins several other states that have set strict...more
On June 29, 2023, Connecticut’s Governor signed into law Substitute Senate Bill No. 1033 which makes significant changes to the state’s Small Loan Act. The new law takes effect on October 1, 2023....more
On May 18, Minnesota Governor Tim Walz signed into law the Commerce Omnibus Bill, which, among other things, amends Minnesota Statute §§ 47.60 and 47.601 to cap the annual percentage rates (APR) on consumer small loans and...more
The Connecticut Department of Banking (“Department”) has issued a temporary cease and desist order (“Order”) that directs SoLo Funds, Inc., (“SoLo”) a fintech company that uses peer-to-peer technology to assist consumers in...more
In opposing efforts by federal and state lawmakers to impose rate caps on small-dollar loans, industry representatives have pointed out the harm that a rate cap can create for consumers, particularly those with less than...more
The “buy now pay later” (BNPL) market continued its trend of increasing valuations and consumer uptake through the end of 2021. BNPL’s popularity is largely due to its simple repayment terms and low cost relative to...more
A recently-released Federal Reserve Board article, “The Cost Structure of Consumer Finance Companies and Its Implications for Interest Rates: Evidence from the Federal Reserve Board’s 2015 Survey of Finance Companies,”...more
The CFPB announced that it has entered into a consent order with Main Street Personal Finance, Inc. and two subsidiaries (Main Street), each a small-dollar lender, to settle the CFPB’s allegations that Main Street (1)...more
In an update to the Frequently Asked Questions (FAQ) post on the U.S. Department of the Treasury (Treasury) website on May 13, 2020, the U.S. Small Business Administration (SBA) and Treasury announced new safe harbor...more
This week LenderLaw Watch covers developments related to small-dollar loans in response to the COVID-19 crisis. Every year the Board of Governors of the Federal Reserve System (Federal Reserve) conducts its Survey of...more
In February 2019, the CFPB released the highly anticipated revamp of its Payday Rule, reinforcing its more lenient attitude towards payday lenders. In light of the Bureau’s softer touch, as well as similar developments at the...more
A recent FDIC request for information (RFI) suggests the FDIC is interested in enabling banks to offer small, short-term loans to consumers. Over the coming weeks the FDIC will be taking comments on the matter. After...more