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Consumer Financial Products Financial Regulatory Reform Electronic Fund Transfer Act

Ballard Spahr LLP

CFPB Reminds Financial Institutions to Retain Records of Affirmative Consent for Overdraft Opt-in

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On September 17, 2024, the CFPB issued Consumer Financial Protection Circular 2024-05 on improper overdraft practices. The circular reminded financial institutions of their obligation to retain records that prove the consumer...more

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CFPB Releases New Circular on Opt-In Requirements for Overdraft Services

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On September 17, the Consumer Financial Protection Bureau (CFPB or Bureau) published Circular 2024-05 (Circular) addressing whether a financial institution violates the Electronic Fund Transfer Act (EFTA) and Regulation E by...more

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FTC Issues 2023 Staff Report on Actions Related to Credit, Leases, and Electronic Fund Transfers

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On May 28, the Federal Trade Commission (FTC) released its annual report to the Consumer Financial Protection Bureau (CFPB) detailing enforcement and educational activities undertaken in 2023. The report pertains to actions...more

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South Carolina Enacts Earned Wage Access Legislation Requiring Registration, Exempting the Product from Lending Laws

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On May 21, 2024, South Carolina Governor Henry McMaster signed into law the Earned Wage Access Services Act (the “Act”), which will require earned wage access (“EWA”) providers to register annually with the state’s Department...more

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Troutman Pepper Weekly Consumer Financial Services Newsletter - May 2024 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

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FTC provides annual report to CFPB regarding activities in 2023 under consumer financial services laws

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On May 20, 2004, the Federal Trade Commission (“FTC”) sent its annual report to the Consumer Financial Protection Bureau (“CFPB”) highlighting its enforcement actions and initiatives in 2023 under the Truth in Lending Act...more

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Kansas Becomes Fourth State to Enact Earned Wage Access Legislation

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On April 19, Kansas Governor Laura Kelly signed House Bill (HB) 2560 to regulate earned wage access (EWA) products and services. HB 2560 enacts the Earned Wage Access Services Act that requires EWA providers to be licensed by...more

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