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Nevada EWA Legislation Creates Novel Regulatory Framework

In June, the Nevada governor signed SB 290 into law, making Nevada the first state to enact legislation creating a comprehensive statutory framework that specifically defines and regulates the provision of earned wage access...more

CFPB Sues Lease-to-Own Finance Company for Allegedly Deceiving Consumers

On July 19, the CPFB filed a complaint against a lease-to-own finance company, alleging that the company has offered and provided millions of “lease-purchase” and “rental-purchase” financing agreements in ways that have...more

Texas, Louisiana Enact Digital Asset Licensing Legislation

In recent weeks, Texas and Louisiana became the latest states to enact legislation establishing licensure requirements for digital asset service providers. In June, Texas enacted HB 1666, which adds practice restrictions...more

FTC Notifies Online Marketplaces of Obligations Under INFORM Act

On June 20, the FTC announced that it has sent letters to 50 online marketplaces nationwide notifying them about their obligations to comply with the new Integrity, Notification, and Fairness in Online Retail Marketplaces...more

CFPB Highlights Risks of Storing Funds in Digital Payment Apps

On June 1, the CFPB published an issue spotlight and a consumer advisory detailing the risks associated with storing funds on digital payment apps, particularly in the event of a platform’s financial distress. Specifically,...more

Colorado Approves DIDMCA Opt-Out, Raising Concerns for Consumer Credit Access

Earlier this month, the Colorado legislature voted to approve HB23-1229, which would opt the State out of Section 521 of the Depository Institutions Deregulation and Monetary Control Act of 1980 (“DIDMCA”), a federal law...more

CFPB, FTC Continue Crack Down on Debt Relief Schemes

On May 5, the CFPB announced that it has sent payments totaling more than $22 million to approximately 6,500 individuals who were harmed by a Maryland-based debt-relief and credit-repair company that marketed and sold...more

Lawsuit Challenges CFPB Reporting Rule for Small Business Lending

On April 26, an association of Texas state banking organizations and a Texas minority depository institution filed a joint complaint against the CFPB in Texas federal court seeking to invalidate a recently finalized agency...more

Federal Regulators Remain Focused on AI-based Discrimination

On April 25, the CFPB, FTC, EEOC, and Civil Rights Division of the DOJ issued a joint statement outlining the agencies’ collective commitment to monitor the development and use of automated systems and artificial intelligence...more

CFPB Statement of Interest Highlights Focus on Discriminatory Access to Credit

On April 14, the CFPB filed a statement of interest in a case currently pending before the United States District Court for the Southern District of Florida in an attempt “to help protect consumers from discriminatory...more

CFPB Director Elevates Priorities for Data Privacy & Repeat Offenders

On April 4, CFPB Director Rohit Chopra delivered remarks at the International Association of Privacy Professionals’ Global Policy Summit on the importance of reigning in repeat violators of consumer finance and privacy laws....more

CFPB Issues Guidance on “Abusive” Conduct in Financial Markets

On April 3, the CFPB issued a policy statement explaining the legal prohibition on “abusive” conduct in consumer financial markets provided in the Consumer Financial Protection Act (CFPA) and provided a summary past...more

NYDFS Examination of Crypto Payment Service Provider Ends in Settlement

On March 16, NYDFS entered a consent order resolving an examination of a payment service provider that allows merchants to accept Bitcoin payments from customers in exchange for the equivalent value in local currency credited...more

CFPB, FTC Seek Public Comment on Tenant Background Checks

On February 28, 2023, the FTC and the CFPB issued a joint request for information (“RFI”) seeking public comment on background checks used to screen potential tenants for rental housing...more

CFPB Report Details Financial Profiles of BNPL Borrowers

On March 2, the CFPB published a report analyzing the financial profiles of consumers who borrow through buy now, pay later (BNPL) lending products. The report found that BNPL borrowers on average are more likely to be active...more

Recent CFPB Actions Focus on Protecting Military Families

On February 23, the CFPB issued a consent order penalizing an auto finance company for allegedly violating the financial rights of military families and other consumers in providing auto title loans. The CFPB found that the...more

Massachusetts AG Settles Enforcement Action Against Auto Lender

On February 2, the Massachusetts Attorney General announced that her office entered into an assurance of discontinuance with an auto loan provider to settle allegations of certain illegal auto loan collection practices....more

Latest CFPB Rule Proposal Takes Aim at Credit Card Late Fees

On February 1, the CFPB announced a newly proposed rule aimed at ensuring that late fees charged on consumer credit card accounts are “reasonable and proportional” to late payments. If finalized, the proposed rule would amend...more

Fed Board Denies Crypto Firm’s Bid to Join Federal Reserve System

On January 27, the Federal Reserve Board (FRB) announced that it unanimously voted to deny a crypto firm’s application to become a member of the Federal Reserve System. This denial ends the crypto firm’s 27-month effort to...more

Colorado AG Secures Latest Settlement over Unearned GAP Fees

On January 4, the Colorado Attorney General announced that his office entered into assurances of discontinuance (available...) with two credit unions that will result in $4 million being refunded to Colorado borrowers who...more

Iowa AG Usury Investigation into Bank Partnership Ends in Settlement

In December, a Utah-based bank and its service provider entered into an assurance of discontinuance with the Iowa Attorney General and the Iowa Division of Banking, settling an investigation into allegedly usurious...more

CFPB and New York AG File Suit Against “Predatory” Auto Lender

On January 4, the CFPB and the New York State Office of the Attorney General filed a complaint against a prominent subprime auto lender in the Southern District of New York. The complaint alleges that the auto lender...more

CFPB and State Regulators Hone in on Interest-Bearing Crypto Accounts

On November 22, the CFPB denied a crypto lending institution’s petition for an order modifying a pending civil investigative demand (“CID”) that the Bureau issued to the institution in December of 2021. The CFPB issued the...more

CFPB Targets Financial Services Company for Deceptive Advertising

On December 1, the CFPB and a financial services company filed a stipulated proposed court order seeking the resolution of a CFPB suit alleging that the financial services company made false, misleading, and inaccurate...more

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