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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 Says Earned Wage Access Products are Subject to the Truth in Lending Act

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...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

An In-Depth Analysis of the CFPB's Proposed Overdraft Rule — Payments Pros – The Payments Law Podcast [Audio]

In this episode of Payments Pros, Josh McBeain and Chris Willis discuss the Consumer Financial Protection Bureau's (CFPB) proposed rule on overdraft fees. The rule, which only applies to large financial institutions with...more

An In-Depth Analysis of the CFPB’s Proposed Overdraft Rule - The Consumer Finance Podcast [Audio]

In this episode of The Consumer Finance Podcast, Chris Willis and Josh McBeain discuss the Consumer Financial Protection Bureau’s (CFPB) proposed rule on overdraft fees. The rule, which only applies to large financial...more

The War on Fees Intensifies: Presidential Strike Force and Industry’s Legal Counterattack

As discussed here, earlier last week the Consumer Financial Protection Bureau (CFPB or Bureau) finalized its credit card late fee rule (Final Rule). The Final Rule sets a safe harbor amount for late fees at $8 and eliminates...more

CFPB Continues War on Fees, Even Rare Ones

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with request for public comment to prohibit covered financial institutions from charging nonsufficient funds fees (NSF) for payment...more

New Year Same Focus on Fees: CFPB Proposes to Amend Regulation Z to Raise New Barriers to Overdraft Charges

On January 17, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with request for public comment to amend exemptions to Regulation Z so the Truth in Lending Act (TILA)/Regulation Z would apply...more

California Federal Court Denies DFPI’s Motion to Dismiss: Finds Commercial Financing Disclosure Regulations May Violate First...

In a recent decision, a federal district court for the Central District of California denied a motion to dismiss filed by the Commissioner of the California Department of Financial Protection and Innovation (DFPI) finding...more

CFPB Determines States’ Commercial Financing Disclosure Laws Are Not Preempted by TILA

As discussed here, on December 7, the Consumer Financial Protection Bureau (CFPB or Bureau) made a preliminary conclusion that New York’s Commercial Financing Law (the New York law) was not preempted by the Truth in Lending...more

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