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CFPB Says Creditors Must Provide Reasons For Taking Adverse Action, Even When Relying On AI

On May 26th, 2022, the Consumer Financial Protection Bureau (“CFPB”) published a Consumer Financial Protection Circular (the “Circular”), confirming that creditors must provide specific reasons for taking adverse action...more

Illinois Imposes 36% MAPR Rate Cap On Consumer Loans; Takes Aim At Fintech-Bank Partnerships And Secondary Market Transactions

On March 23, 2021, the Predatory Loan Prevention Act (the “PLPA”) was signed into law by Illinois Governor J.B. Pritzker. The PLPA imposes a 36% military annual percentage rate (“MAPR”) cap on all loans made to Illinois...more

Fair Lending Considerations In A COVID-19 World: Fair Servicing And Consumer Relief In The U.S.

The sudden financial impact of the COVID-19 pandemic on consumers has led to calls for loan servicers and other interested parties to provide temporary or permanent relief for borrowers who are unable to continue making loan...more

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