Last Week, the Consumer Financial Protection Bureau (CFPB) announced that its so-called “Payday, Vehicle Title and Certain High-Cost Installment Loans” rule (Rule) will go into effect on March 30, 2025. While ostensibly aimed...more
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
Rhode Island, Minnesota, and Nevada have joined the list of jurisdictions considering proposals to legislatively opt out of federal interest rate preemption established under the federal Depository Institutions Deregulation...more
After targeting credit card late fees in its proposed rule, the CFPB has set its sights on further attacking credit card pricing through interest rates. The CFPB published a blog late last month stating that credit card...more
Recently, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its first report on the results of its updated Terms of Credit Card Plans survey. The report found that for the first half of 2023, small banks and...more
After being the first state to impose disclosure requirements on small business finance transactions, California has now added an annual reporting requirement and subjected commercial finance companies to UDAAP claims. On...more
Minnesota recently enacted the Commerce Omnibus Finance Bill, which includes amendments to several provisions of Minnesota law related to consumer loans and financial institutions....more
U.S. states continue to consider and adopt statutes requiring TILA-like disclosures in connection with various types of commercial financing transactions. Most recently, Georgia passed a law, effective January 1, 2024,...more
On March 29, Kentucky enacted SB 165 to amend Kentucky code to modify permitted loan charges for consumer loan companies. Specifically, licensees may make loans up to $15,000, excluding charges; however, the original...more
The Illinois Department of Financial and Professional Regulation (IDFPR) has adopted a series of regulations pursuant to the Illinois Predatory Loan Prevention Act (PLPA). The new regulations will require certain Illinois...more
The New York Department of Financial Services (NYDFS) has issued “pre-proposed” rules under New York’s commercial financing disclosure law that was enacted at the end of 2020. The pre-proposed rules are 45 pages in length...more
Illinois House Bill 2746, also known as the “Know Before You Owe Private Education Loan Act,” was signed into law by Illinois Governor J.B. Pritzker on August 26, 2021, after unanimous passage in both chambers of the Illinois...more
As expected, New York has broadened the reach of its new commercial financing disclosure law less than two months after its enactment. S.B. 5470, as previously reported by Mayer Brown, imposed a range of Truth in Lending-like...more
When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more
On January 31, 2020, by a vote of 65 to 33, the Virginia House of Delegates passed a bill that would establish a 36% rate cap on certain consumer loans. Since Democrats also hold a majority in the Virginia Senate, the Senate...more
The bulletin issued this week by the OCC encouraging the banks it supervises “to offer responsible short-term, small-dollar installment loans” quickly met with mixed reviews from consumer advocates....more