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Credit Financial Institutions Loans

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

White & Case LLP

Liability management transactions give borrowers some breathing room

White & Case LLP on

Although liability management transactions have been controversial, they can provide borrowers a valuable respite in tough times when used appropriately - High interest rates and circumspect capital markets have caused...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Cadwalader, Wickersham & Taft LLP

Give Me Some Credit July 2023 - Can I Get Some (Credit) Support?

With the recent wave of displacements occurring in our industry, we have been fielding a higher level of calls from clients looking for a “cheat sheet” that they can pass along to their new credit officers who have varying...more

Cadwalader, Wickersham & Taft LLP

‘I’ll Be There for You’ December 2022 | Issue No. 203 - Fund Finance Credit Availability in 2023: Not Just Banks

As remarkable as the year has been for banks, 2022 will be remembered in part for the continued ascent of private credit. The scale and significance of these non-bank lenders became clear this summer when private credit funds...more

Alston & Bird

Second Circuit’s Madden v. Midland Decision Could Upend Secondary Credit Markets

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The Second Circuit Court of Appeals’ May 22, 2015, decision in Madden v. Midland Funding, LLC held that a nonbank entity taking assignment of debts originated by a national bank is not entitled to protection under the...more

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