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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

Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule — Payments Pros – The Payments Law Podcast [Audio]

In this special crossover episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory, Keith Barnett, and Chris Willis are joined by Jason Cover and Mark Furletti to discuss the Consumer Financial Protection...more

Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule — The Consumer Finance Podcast [Audio]

In this special crossover episode of Payments Pros and The Consumer Finance Podcast, Carlin McCrory, Keith Barnett, and Chris Willis are joined by Jason Cover and Mark Furletti to discuss the Consumer Financial Protection...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

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

CFPB's Section 1071 Final Rule (Part 3): Potential Problem Areas – The Consumer Finance Podcast [Audio]

Please join Troutman Pepper Partner Chris Willis and his colleagues Mark Furletti, Joe Reilly, and Christine Emello for the last installment of a special three-part series about the Consumer Financial Protection Bureau’s...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

Illinois Becomes Latest State to Introduce Small Business Truth in Lending Act

On February 16, Illinois State Representative Hoan Huynh (D) introduced HB3064, the Small Business Truth in Lending Act, that would impose certain mandatory disclosure requirements for commercial financing transactions and...more

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

On October 13, the Consumer Financial Protection Bureau, the Federal Reserve Board, and the Office of the Comptroller of the Currency announced increased dollar thresholds used to determine whether certain consumer credit and...more

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