Podcast - Credit Funds: How PE Funds Can Address and Minimize Conflict When Expanding Into Credit
The National Consumer Law Center is asking the CFPB, by way of a petition, for rulemaking that is long on policy arguments but woefully short on legal support, as we note below, to define residential leases as “credit” under...more
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
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...more
In a major win for the CFPB, in CFPB v. Townstone Financial, a panel of the U.S. Court of Appeals for the Seventh Circuit (7th Circuit) recently held that the Regulation B provision prohibiting discrimination under the Equal...more
Kansas Governor Laura Kelly signed House Bill (HB) 2247 into law, bringing significant changes to the Kansas Mortgage Business Act and the Uniform Consumer Credit Code (UCCC). The changes brought about by HB 2247 will largely...more
On March 26, 2024, the President of Mexico published the reform passed by the Mexican Congress to the General Law of Negotiable Instruments and Credit Transactions (Ley General de Títulos y Operaciones de Crédito, “LGTOC”),...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
In recent years, earned wage access (EWA) – an innovative technology that enables workers to access their own, already earned wages without having to wait for payday – has rapidly become a table stakes employee benefit. By...more
For purposes of general applicability of the Truth in Lending Act and Regulation Z to credit transactions and the Consumer Leasing Act and Regulation M for lease transactions, the Consumer Financial Protection Bureau ("CFPB")...more
On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more
On November 2, 2023, the Consumer Financial Protection Bureau issued a report on the community reinvestment laws of seven states (Connecticut, Illinois, Massachusetts, New York, Rhode Island, Washington, West Virginia), and...more
The Office of the Comptroller of the Currency’s (OCC) Committee on Bank Supervision (CBS) recently issued its annual Bank Supervision Operating Plan for FY 2024, which sets forth the OCC’s supervision priorities and...more
What’s New? A new European Union (EU) Directive on Credit Servicers and Credit Purchasers (the Directive) requires investors who acquire, manage, or sell non-performing loans (NPLs), issued by EU-authorised credit...more
On June 14, the Office of the Comptroller of the Currency (OCC) published the spring edition of its Semiannual Risk Perspective, which discusses key issues facing banks. The good news is that the federal banking system saw...more
The Consumer Financial Protection Bureau’s adopting release for its small business data collection and reporting rule goes beyond that rule by including a discussion deeming merchant cash advances to be “credit” more...more
On January 23, the Colorado attorney general announced that it sent a study examining the availability of consumer lending in the state to the Colorado General Assembly....more
The Consumer Financial Protection Bureau (“CFPB”) released a regulatory Circular providing guidance regarding the use of “complex algorithms” to assess whether a consumer should be extended credit. Often referred to as “black...more
Payday Lending Market Investigation Order 2015: CMA summary of borrowing template - The Competition and Markets Authority (CMA) has published a template of a summary of borrowing statement, to be used by lenders to comply...more
If the current pandemic has taught us anything, it is that we depend on each other for in-person contact more than we thought. This is especially true for unbanked and underbanked consumers seeking financial services....more