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Consumer Financial Products Financial Services Industry Disclosure

White & Case LLP

Side Letters: Just Paper Tigers, Or Do They Roar?

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Side letters document bespoke arrangements between all or certain parties to a financing transaction and supplement the terms of the principal documents thereto. Becoming increasingly popular with stakeholders, and with the...more

Klein Moynihan Turco LLP

CFPB Releases Comparison Shopping Warning

On January 29, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued a circular (the “Circular”) detailing what it considers deceptive financial services marketing practices under the Consumer Financial Protection...more

Perkins Coie

California DFPI Orders Consumer Financing Platform To Cease Hidden Junk Fees

Perkins Coie on

On January 9, the California Department of Financial Protection and Innovation (DFPI) issued an order against a consumer financing platform that enables merchants to offer installment contracts to their customers. The...more

Perkins Coie

N.Y. Governor Proposes Measures To Ensure Fairness in “Buy Now Pay Later” Services

Perkins Coie on

On January 2, New York Governor Kathy Hochul announced a proposal to establish regulations for the “Buy Now Pay Later” (BNPL) loan industry. Gov. Hochul announced that she will propose legislation to require BNPL providers...more

Orrick, Herrington & Sutcliffe LLP

DFPI modifies CCFPL proposal

On February 24, the California Department of Financial Protection and Innovation (DFPI) released modifications to proposed regulations for implementing and interpreting certain sections of the California Consumer Financial...more

Orrick, Herrington & Sutcliffe LLP

California: TILA does not preempt state laws on commercial financial disclosure

On January 20, California Attorney General Rob Bonta sent a comment letter to CFPB Director Rohit Chopra in response to a preliminary determination issued by the Bureau in December, which concluded that commercial financial...more

Ballard Spahr LLP

IRS Issues Clarification Regarding Taxpayer First Act Disclosure of Information Provision

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The Taxpayer First Act adopted in the summer of 2019 includes the following provision that has an effective date of December 28, 2019...more

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