Washington recently enacted significant changes to its Consumer Loan Act that may bring certain nonbank loan marketers and program managers within its scope. The Consumer Loan Act requires a license to make consumer loans of...more
In addition to the states that, similar to Washington, have adopted “true lender” provisions, several states have recently enacted changes to their consumer loan licensing laws that expand the scope of the licensing...more
The CFPB has launched an aggressive campaign against so-called “junk fees.” This year the CFPB has released proposed rules targeting overdraft and non-sufficient funds fees and a final rule targeting credit card late fees....more
In December, the State of Iowa and the Iowa Division of Banking entered into an Assurance of Discontinuance (“AOD”) with Transportation Alliance Bank, Inc. (the “Bank”) settling claims that the Bank charged usurious rates of...more
1/13/2023
/ Assurance of Discontinuation (AOD) ,
Banks ,
Consumer Financial Products ,
Consumer Lenders ,
DIDMCA ,
Financial Services Industry ,
Interest Rates ,
Internet Lenders ,
Opt-Outs ,
Settlement Agreements ,
True Lender ,
Usury
It is widely anticipated that the London Interbank Offered Rate (“LIBOR”) will be discontinued in 2021. As LIBOR commonly is used as an index rate for both residential mortgage and consumer loans, its discontinuance has the...more
1/30/2020
/ Adjustable Rate Financial Products ,
Adjustable-Rate Mortgage ,
Alternative Reference Rates Committee (ARRC) ,
Consumer Financial Products ,
Consumer Lenders ,
Consumer Loan Companies ,
Financial Services Industry ,
Interest Rates ,
Libor ,
Loans ,
Mortgages ,
NYDFS ,
Regulatory Oversight ,
Secured Overnight Funding Rate (SOFR) ,
Transitional Arrangements