News & Analysis as of

Consumer Lenders Regulation Z Financial Institutions

Ballard Spahr LLP

CFPB files and prosecutes yet another enforcement lawsuit using funds obtained in violation of the CFPB’s enabling statute...

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The Introduction to the Complaint which was filed by the CFPB on May 17, 2024 against Solo Funding, Inc. in the United States District Court for the Central District of California – Western Division Los Angeles (Judge R. Gary...more

Troutman Pepper

CFPB Advises Against Certain Contract-for-Deed Practices

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This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion and a research report addressing contract-for-deed home financing, also known as a “land contract,” “land installment contract,”...more

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

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 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

Ballard Spahr LLP

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

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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

Stinson LLP

New CFPB Interpretive Rule to Regulate BNPL

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The Consumer Financial Protection Bureau (CFPB ) has issued an interpretive rule stating that Buy Now, Pay Later (BNPL) loan providers are "card issuers" under Subpart B of Regulation Z and are thus subject to certain...more

Ballard Spahr LLP

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

Troutman Pepper

9 Consumer Finance Issues to Note From CFPB Report

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In July, the Consumer Financial Protection Bureau published a report highlighting various unfair, deceptive, and abusive acts or practices it claims to have uncovered during its supervisory examinations from July 2022 to...more

Hudson Cook, LLP

CFPB Bites of the Month - October Top 10: Ghosts, Goblins & the Spooky CFPB

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In this month's Top 10 article, we share some of our top "bites" for the prior month covered during the October 19, 2022, webinar. So, what happened last month? Extra Bite: CFPB Releases Special Edition of Supervisory...more

Ballard Spahr LLP

CFPB Publishes TRID FAQs on Treatment of Lender Credits

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The CFPB recently published 10 new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more

Ballard Spahr LLP

CFPB Publishes TRID FAQ’s on Treatment of Lender Credits

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The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more

Ballard Spahr LLP

CFPB updates TRID Rule small entity compliance guide

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The CFPB recently released a revised version of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October...more

Ballard Spahr LLP

CFPB files lawsuit against pawnbroker for alleged TILA and CFPA violations

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The CFPB announced that it filed a lawsuit in a Virginia federal district court against B&B Pawnbrokers, Inc., for alleged violations of the Truth in Lending Act and the Consumer Financial Protection Act in connection with...more

Ballard Spahr LLP

CFPB issues final rule expanding definition of “small creditor” and “rural areas” under TILA

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The CFPB has issued a final rule that revises the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA). The final rule is effective January 1, 2016. We previously reported on...more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA and QM adjustments

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The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

Davis Wright Tremaine LLP

Revised Military Lending Act Rules Impose New Compliance Obligations on a Wide Variety of Creditors

The Department of Defense (DOD) recently finalized amendments to its Military Lending Act (MLA) regulations that impose new compliance obligations on a wide variety of creditors, including issuers of credit cards and...more

WilmerHale

Department of Defense Issues Final Rule Expanding Military Lending Act to Credit Cards and Other Consumer Lending Products

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On July 21, 2015, the U.S. Department of Defense (“DOD”) announced the final rule amending the Military Lending Act’s (“MLA”) implementing regulations. The changes apply the MLA’s strict lending restrictions to consumer...more

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