Increased regulation of commercial financing shows no signs of stopping. California SB 1482, which would require commercial financing providers and brokers to register with the California Department of Financial Protection...more
6/6/2024
/ California ,
Consumer Financial Products ,
Department of Financial Protection and Innovation (DFPI) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financing ,
Lenders ,
Loans ,
NMLS ,
Proposed Legislation ,
Registration Requirement ,
Regulatory Agenda
To the likely surprise of providers of buy now, pay later (“BNPL”) financing, last week the Consumer Financial Protection Bureau (“CFPB”) issued an interpretive rule stating that BNPL products are actually “credit cards”...more
On September 8, 2023, the U.S. District Court for the Eastern District of Texas issued an opinion and order vacating a March 2022 anti-discrimination update to the UDAAP section of the Consumer Financial Protection Bureau’s...more
After being the first state to impose disclosure requirements on small business finance transactions, California has now added an annual reporting requirement and subjected commercial finance companies to UDAAP claims. On...more
8/22/2023
/ Annual Percentage Rate (APR) ,
Annual Reports ,
California ,
Department of Financial Protection and Innovation (DFPI) ,
Disclosure Requirements ,
Final Rules ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financial Transactions ,
UDAAP ,
Unfair or Deceptive Trade Practices
U.S. states continue to consider and adopt statutes requiring TILA-like disclosures in connection with various types of commercial financing transactions. Most recently, Georgia passed a law, effective January 1, 2024,...more
On January 4, 2023, the Consumer Financial Protection Bureau (“CFPB”) and New York Attorney General (“NYAG”) filed a complaint in the Southern District of New York against a Michigan-based subprime indirect auto lender...more
In an effort to clarify the regulatory framework applicable to new education financing methods such as Income Share Agreements (“ISAs”), installment payment plans and other alternative financing methods, the California...more
July 5 is the deadline for submitting comments on the California Department of Financial Protection and Innovation’s (DFPI) proposed regulations on complaint handling and reporting, which would impose significant obligations...more
6/14/2022
/ Banking Sector ,
California ,
California Consumer Financial Protection Law (CCFPL) ,
Comment Period ,
Consumer Complaint Management ,
Consumer Complaint System ,
Department of Financial Protection and Innovation (DFPI) ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Proposed Regulation ,
Regulatory Agenda ,
Regulatory Burden