News & Analysis as of

Financial Services Industry Income Share Agreements Department of Financial Protection and Innovation (DFPI)

Ballard Spahr LLP

California Finalizes Registration Requirements for Providers of Earned Wage Access, Other Financial Products and Services

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On October 11, California’s Office of Administrative Law (“OAL”) approved the Department of Financial Protection and Innovation’s (“DFPI’s”) registration rulemaking for providers of the following products...more

Ballard Spahr LLP

CFPB Takes Action Against BloomTech, Inc. for ISAs that Violate TILA, UDAAP, and the FTC’s Holder Rule

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On April 17th, the CFPB issued a consent order to a for-profit training school alleging numerous violations of law related to its use if income share agreements (“ISAs”). According to the Bureau, BloomTech, Inc. (“BloomTech”)...more

Ballard Spahr LLP

California DFPI Finalizes Regulations Governing Student Loan Servicers

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On October 13, 2023, the California Department of Financial Innovation (DFPI) published final regulations implementing the Student Loan Servicing Act (“SLSA”) and the Student Loans: Borrower Rights Law. The final regulations...more

Troutman Pepper

California Finalizes Amendments to Student Loan Servicing Act

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On October 12, in its monthly bulletin the California Department of Financial Protection and Innovation (CA DFPI) announced that final regulations to implement the Student Loan Servicing Act and the Student Loans Borrower...more

Ballard Spahr LLP

CFPB and 11 states file lawsuit against companies engaged in origination and collection of income share agreements

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The Consumer Financial Protection Bureau, the California Department of Financial Protection and Innovation (CA DFPI), and ten state Attorneys General have filed a lawsuit against Prehired, LLC (Prehired) and two related...more

Orrick, Herrington & Sutcliffe LLP

DFPI modifies Student Loan Servicing Act proposal

On January 6, the California Department of Financial Protection and Innovation issued modified proposed regulations under the Student Loan Servicing Act (Act)...more

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