News & Analysis as of

Consumer Financial Products Truth in Lending Act (TILA) Comment Period

Nelson Mullins Riley & Scarborough LLP

Who is Paying Who: The Employee or the Employer?

Since 2022, the Consumer Financial Protection Bureau (CFPB) has a stated priority of “protecting employees and their rights through conducting reports, inquiries, and issuing requirements for employers.” In July 2024, the...more

Ballard Spahr LLP

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

Ballard Spahr LLP on

On July 18, 2024, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) proposed an interpretive rule that states (1) EWA products fall under the definition of “credit” under the Truth in Lending Act (“TILA”) and...more

Cadwalader, Wickersham & Taft LLP

CFPB Again Seeks Demise of Overdraft or NSF Fees, Part 1

In January 2024, the Consumer Financial Protection Bureau ("CFPB") issued two proposed rules that, if implemented as written, would result in further whittling down overdraft or non-sufficient funds ("NSF") fees charged by...more

Troutman Pepper

New Year Same Focus on Fees: CFPB Proposes to Amend Regulation Z to Raise New Barriers to Overdraft Charges

Troutman Pepper on

On January 17, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with request for public comment to amend exemptions to Regulation Z so the Truth in Lending Act (TILA)/Regulation Z would apply...more

Goodwin

Tougher Standards for Certain Home Improvement Loans

Goodwin on

On May 1, 2023, the Consumer Financial Protection Bureau (CFPB) issued a report and a proposed rule to clarify and strengthen its regulation of so-called Property Assessed Clean Energy (PACE) financing. PACE financing is...more

Ballard Spahr LLP

You Can Still Comment on the TRID Rule Assessment

Ballard Spahr LLP on

As we previously reported, the CFPB is conducting an assessment of the TILA/RESPA Integrated Disclosure (TRID) Rule. Although the comment period associated with the Federal Register notice regarding the assessment ended on...more

Ballard Spahr LLP

CFPB announces enforcement actions against auto title lenders

Ballard Spahr LLP on

The CFPB announced that it has filed administrative enforcement actions against five Arizona auto title lenders for alleged violations of Truth in Lending Act advertising requirements. According to the CFPB, the lenders...more

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