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

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

CFPB Tries to Stretch Section 1057 of the CFPA to Reach Nondisclosure Agreements

This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued Circular 2024-04 warning financial institutions about the potential illegality of nondisclosure agreements (NDAs) that could deter whistleblowing....more

CFPB Rules Buy Now, Pay Later Lenders Must Offer Key Credit Card Protections

Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an “interpretive rule,” subjecting “Buy Now, Pay Later” (BNPL) transactions to provisions of Regulation Z applicable to “credit cards.” Among other...more

Wisconsin Legislature Passes Earned Wage Access Bill

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

Massachusetts Introduces Earned Wage Access Product Legislation

On February 15, Massachusetts became the latest state to introduce legislation to regulate earned wage access (EWA) products and services. House Bill (HB) 4456 would create a new chapter to the Massachusetts Code explicitly...more

A CFPB First: Bureau Publicly Asserts “Dormant” Supervisory Authority Over Company

On February 23, the Consumer Financial Protection Bureau (CFPB or Bureau) released an order, dated November 30, 2023, establishing supervisory authority over installment lender World Acceptance Corp. The CFPB found that it...more

Understanding the CFPB's Proposed Digital Payments Larger Participants Rule and Its Implications for Digital Assets — The Crypto... [Audio]

In this special joint episode of Payments Pros and The Crypto Exchange, Ethan Ostroff, James Kim, and Carlin McCrory discuss the Consumer Financial Protection Bureau's (CFPB) proposed rule to supervise large tech companies...more

Year in Review and a Look Ahead: Fintech Developments — The Consumer Finance Podcast [Audio]

Join us for the second episode of our Year in Review and a Look Ahead series, where we delve into the fintech world. Our host, Chris Willis, co-leader of Troutman Pepper's Consumer Financial Services Regulatory practice, is...more

NY Governor Announces Plans to Regulate “Buy Now, Pay Later” Industry

On January 2, New York Governor Kathy Hochul unveiled her 2024 consumer protection agenda, which includes plans to regulate the “buy now, pay later” (BNPL) industry. Specifically, Governor Hochul plans to propose legislation...more

Washington D.C. Introduces Legislation Attacking Fintech-Bank Partnership Lending by Opting Out of DIDMCA and Codifying a “True...

Late last month, Councilmember Kenyan R. McDuffie introduced B 25-0609, entitled the Protecting Affordable Loans Amendment Act of 2023, that proposes to opt the District of Columbia out of sections 521-523 of the Depository...more

CFPB Reports That College-Sponsored Financial Products Have Higher Fees and Less Favorable Terms

The Consumer Financial Protection Bureau (CFPB or Bureau) released its 14th annual report to Congress in fulfillment of its requirements under the Credit Card Accountability Responsibility and Disclosure (CARD) Act. For the...more

The Future of Digital Consumer Payment Applications: CFPB's Proposed Larger Participant Rule – The Consumer Finance Podcast and... [Audio]

In this special joint episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory, Keith Barnett, James Kim, and Chris Willis discuss the Consumer Financial Protection Bureau's (CFPB) proposed larger participant...more

Arizona AG Concludes Non-Recourse, No-Interest Earned Wage Access Products Are Not “Consumer Lender Loans” Requiring a License

Arizona Attorney General Mark Brnovich released opinion No. 22-(R22-011), concluding earned wage access (EWA) products that are fully non-recourse and no-interest are not “consumer lender loans” under Arizona law. Thus, those...more

CFPB Partners With Local Governments to Protect Consumers

On November 18, the Consumer Financial Protection Bureau (CFPB) published a blog post outlining its recent initiative to share consumer complaint data with cities and counties so they can, “increase their efforts to protect...more

Fifth Circuit Finds CFPB Funding Structure Unconstitutional

In a major decision released October 19, a three-judge panel of the Fifth Circuit Court of Appeals found the funding mechanism for the Consumer Financial Protection Bureau (CFPB or Bureau) to be unconstitutional....more

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