Business Better Podcast Episode: FinCEN’s Notice of Proposed Regulations to Strengthen and Modernize AML/CFT Compliance Programs
FTC CFPB Enforcement Report — Moving the Metal: The Auto Finance Podcast
Earned Wage Access: Exploring the CFPB's Proposed Interpretive Rule — The Consumer Finance Podcast
CFPB's New Interpretive Rule: Buy Now, Pay Later as Credit Cards — The Consumer Finance Podcast and Payments Pros Podcast
Consumer Finance Monitor Podcast Episode: California Consumer Finance Law - Hot Topics and Recent Developments
Consumer Finance Monitor Podcast Episode: What Banking Leaders Need to Know About the U.S. Supreme Court Ruling That the CFPB’s Funding Mechanism is Constitutional Part II
Redlining Complications Caused by Implementation of 2020 Census Tracts
Consumer Finance Monitor Podcast Episode: What Banking Leaders Need to Know About the U.S. Supreme Court Ruling That the CFPB’s Funding Mechanism is Constitutional Part I
Third-Party Risk Management in Bank-Fintech Partnerships: Strategies and Insights — Payments Pros – The Payments Law Podcast
Consumer Finance Monitor Podcast Episode: An Insider’s View of the CFPB
Consumer Finance Monitor Podcast Episode: Banks and Their Customer Relationships: What is the Appropriate Role of Bank Regulators?
An In-Depth Analysis of the CFPB's Proposed Overdraft Rule — Payments Pros – The Payments Law Podcast
Auto Finance – The Holder Rule — The Consumer Finance Podcast
Understanding the CFPB's Rules for Risk-Based Nonbank Supervision — The Consumer Finance Podcast
The Kirtz Decision: FCRA and Government Liability Unpacked — FCRA Focus Podcast
Will Resiliency Carry the Digital Asset Sector Through 2024: Navigating the 2023 Regulatory Landscape — The Crypto Exchange Podcast
Consumer Finance Monitor Podcast Episode: A Close Look at the Consumer Financial Protection Bureau’s Final Credit Card Late Fee Rule: Have Cardholders Been Dealt a Winning or Losing Hand?
Navigating Facility Relocation: Legal and Practical Considerations — Regulatory Oversight Podcast
Tackling Credit Push Fraud: Understanding Nacha's Risk Management Package (Part One) — Payments Pros: The Payments Law Podcast
The CFPB's Rule to Remove Medical Debt from Credit Reports
On 30 July 2024, the United Kingdom Financial Conduct Authority (“FCA”) published a number of updates in relation to its work on complaints against motor finance firms. In particular, the FCA published an update...more
Florida recently enacted H1347, revising the state’s criteria for what constitutes usurious consumer loans. The Florida Consumer Finance Act prohibits charging an interest rate of more than 18% per year on a loan of...more
In the same 2023 bill (House Bill 23-1229) that included Colorado’s DIDMCA opt-out**, Colorado adopted a statute excepting certain “general-purpose credit cards”, as defined, from the state’s limitations on finance charges...more
The U.S. Department of Veterans Affairs (VA) recently proposed rules under its home loan guaranty program regarding adjustable rate mortgage (ARM) loans, hybrid ARM (h-ARM) loans and temporary buydown agreements. Comments are...more
Last Week, the Consumer Financial Protection Bureau (CFPB) announced that its so-called “Payday, Vehicle Title and Certain High-Cost Installment Loans” rule (Rule) will go into effect on March 30, 2025. While ostensibly aimed...more
Colorado’s attempt to opt out of interest rate exportation by out-of-state, state-chartered banks ultimately will fail, and will cause irreparable harm in the interim: therefore, enforcement of the opt out should be...more
As we previously reported, on March 25, 2024, three consumer financial services industry trade groups filed a lawsuit in federal district court in Colorado challenging legislation recently adopted to opt out of rate...more
Monday, three trade organizations filed a complaint in Colorado federal court challenging H.B. 1229, Colorado’s effort to limit interest charges by out-of-state financial institutions, which is set to take effect on July 1,...more
On March 25, 2024, three consumer financial services industry trade groups filed a lawsuit asking the federal district court in Colorado to strike down recent Colorado legislation purporting to opt out of a federal law that...more
In 1980, Congress passed Public Law 96-221, called the Depository Institutions Deregulation and Monetary Control Act (“DIDMCA”), which, in part, allowed federally insured state banks, state credit unions, and state savings...more
Rhode Island, Minnesota, and Nevada have joined the list of jurisdictions considering proposals to legislatively opt out of federal interest rate preemption established under the federal Depository Institutions Deregulation...more
After targeting credit card late fees in its proposed rule, the CFPB has set its sights on further attacking credit card pricing through interest rates. The CFPB published a blog late last month stating that credit card...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 representing fintech companies and other lenders, we increasingly confront claims against debt buyers or entities with bank partner relationships brought under Pennsylvania’s Consumer Discount Company Act (CDCA) and the...more
In a new data spotlight issued last week, the Consumer Financial Protection Bureau (“CFPB”) found that interest rates charged on credit cards issued by large banks are higher than interest rates charged on credit cards issued...more
On February 12, ten Rhode Island senators introduced S 2275, a bill proposing to opt Rhode Island out of §§ 521-523 of the Depository Institutions Deregulation and Monetary Control Act (DIDMCA). On February 13, HF 3680 was...more
As we kick off 2024, the focus on the unavailability of certain benchmarks continues on. To refresh, we have already seen the benchmark for US Dollars generally replaced with the Secured Overnight Financing rate as...more
District of Columbia Council Bill B 25-0609, which would opt out of Section 27 of the Federal Deposit Insurance Act (“FDIA”) with respect to loans made in the District of Columbia, was introduced in the District of Columbia...more
A California state court recently denied a preliminary injunction sought by the California Department of Financial Protection and Innovation (the DFPI) in its long-running litigation against Opportunity Financial (OppFi)...more
FTC Amends Safeguards Rule to Require Non-Banking Financial Institutions to Report Data Security Breaches - “Amendment will require non-bank financial institutions to report when they discover that information affecting...more
El Banco de México (Banxico), el 13 de abril de 2023, publicó en el Diario Oficial de la Federación la Circular 3/2023 dirigida a Instituciones de Crédito y Sociedades Financieras de Objeto Múltiple Reguladas relativa a las...more
As we finish the last season of LIBOR replacement, the fund finance market is busy amending our loan documents to include SOFR as the interest rate benchmark for U.S. dollar loans. While the cessation date for USD LIBOR is...more
On April 3, 2023 the U.K. Financial Conduct Authority (“FCA”) announced that it will require the administrator of U.S. dollar LIBOR to continue to publish one, three and six-month U.S. dollar LIBOR settings until September...more
On December 16, 2022, the Board of Governors of the Federal Reserve System (the “Board”) adopted a final rule (the “Final Rule”) to implement the Adjustable Interest Rate (LIBOR) Act (the “LIBOR Act”). The Final Rule follows...more