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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

Florida Consumer Finance Act Amendments Take Effect

On July 1, amendments to Florida’s Consumer Finance Act took effect. Among other things, the amendments raise the maximum tiered interest rates on consumer finance loans, increase the grace period before late fees can be...more

CFPB Files Lawsuit Against SoLo Funds for Alleged Deceptive Lending Practices

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) filed a complaint against SoLo Funds, Inc., a fintech company operating a small-dollar, short-term lending platform. The CFPB alleges that SoLo Funds...more

OCC Issues “Buy Now, Pay Later” Guidance to Banks

This week, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are...more

Nebraska Enacts Loan Licensure Requirement for Marketers, Servicers and Purchasers of Interests in Certain Bank Loans

On June 6, Nebraska Governor Jim Pillen signed into law Legislative Bill 92, which, among many other subjects, amends the Nebraska Installment Loan Act (the NILA). Previously, a license was required for a lender seeking to...more

Minnesota Enacts Bill Capping All-In APR and Codifying Predominant Economic Interest Test for Short-Term and Small Consumer Loans

On May 18, Minnesota Governor Tim Walz signed into law the Commerce Omnibus Bill, which, among other things, amends Minnesota Statute §§ 47.60 and 47.601 to cap the annual percentage rates (APR) on consumer small loans and...more

CFPB Issues Analysis on Consumers of Buy Now, Pay Later Products

As we reported here, late last year, the Consumer Financial Protection Bureau (CFPB) signaled that it planned to increase scrutiny of the Buy Now, Pay Later (BNPL) industry and issued its first report about BNPL. Yesterday,...more

New York Adopts Commercial Financing Transaction Disclosure Requirements

On February 1, the Superintendent of Financial Services Adrienne A. Harris announced that the New York State Department of Financial Services completed the process for adopting a new regulation relating to disclosure...more

CFPB Signals Increased Regulation of Buy Now, Pay Later Products

After analyzing public feedback, as well as information gathered from the five providers of Buy Now, Pay Later (BNPL) products, the Consumer Financial Protection Bureau (CFPB) issued a report, making it clear that the CFPB...more

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