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Double Clicking on Innovation in Consumer Finance: Responsible Use of AI

Artificial intelligence (AI) is becoming ubiquitous across sectors, and the financial services industry is no exception. With the rise of AI, there is also an increase in scrutiny by regulators over its use....more

CFPB Departs From Precedent and Reverses Itself by Proposing Novel Interpretive Rule That Applies TILA and Regulation Z to...

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule (Proposed Rule) applying the Truth in Lending Act (TILA) and Regulation Z (collectively referred to hereafter as Regulation Z) to...more

Traps for the Unwary: Using Alternative Credit Data to Expand Credit Access to LMI Individuals and Underrepresented Communities

Traditional credit underwriting methods, which are generally based on credit reports, have not always successfully captured the full picture of a borrower’s ability to repay. It is estimated that more than 45 million US...more

CFPB Deems Merchant Cash Advances to Be “Credit” Under ECOA

The Consumer Financial Protection Bureau’s adopting release for its small business data collection and reporting rule goes beyond that rule by including a discussion deeming merchant cash advances to be “credit” more...more

Fair Lending Considerations in a COVID-19 World: Rules Still in Play

The U.S. banking regulators and state attorneys general have issued several appeals to the financial services industry to assist borrowers in financial distress due to the COVID-19 pandemic. These agencies have publicly...more

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