A Discussion with Nacha on Proposed Rulemaking Regarding Fraud - Payments Pros: The Payments Law Podcast
What Is Mass Arbitration and How Should Companies Protect Themselves? - The Consumer Finance Podcast
California Updates Protections for Service Members and Veterans - The Consumer Finance Podcast
HVCRE: The Continuing Saga of Lenders
The CFPB's Small Business Lending Initiative
In The Cross-Hairs? Protecting Your Company Against Consumer Financial Protection Bureau Investigations and Investors' Mortgage Buyback Claims
Macroeconomic uncertainty has impacted Indonesian debt markets in recent years. But, after a period of disruption, prospects for domestic and offshore debt issuances are brightening....more
Recent news stories explain the criticism of Senator Warren and Congresswoman Waters directed at banks that are litigating the 2023 CRA rule. But perhaps their frustration should be focused on the regulators who have...more
With inflation still affecting the US economy, lenders are now focused on the economic impact of the upcoming presidential election. Lenders’ expectations for the US economy’s performance in the longer term – beyond the next...more
Although high interest rates may no longer be headline news, loan obligations remain a driving source of stress for many business owners. Loan financing is fundamental (and often unavoidable) for many businesses. Loans can...more
With inflation continuing to impact the US economy, lenders are focused on the economic impact of elevated interest rates. Lenders’ expectations for the US economy’s performance in the longer term – beyond the next six months...more
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a report on the state of negative equity in auto lending. The CFPB says it found that financing negative equity creates increased risks for...more
On May 17, the CFPB filed a lawsuit against a California-based fintech that operates a nationwide website and mobile-application based peer-to-peer lending platform through which consumers can obtain small-dollar, short-term...more
With inflation continuing to impact the US economy, lenders are focused on the economic impact of the presidential election in November. Lenders’ expectations for the US economy’s performance in the longer term – beyond the...more
With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers....more
Several national and Texas banking and business trade groups have filed a lawsuit in the U.S. District Court for the Northern District of Texas challenging the final regulations (Final Rules) implementing the Community...more
I have written a number of articles about the new CRA and the problems its requirements will impose on banks. But there are also problems posed by what the new Rule omits....more
Interest rates and inflation have been the big drivers of the US economy as of late, but lenders are increasingly optimistic for 2024, despite some challenges. Lenders foresee interest rate declines beginning in 2024 – with...more
One of the most important CRA responsibilities for Intermediate-Small Banks and Large Banks is "Community Development Lending". But while Community Development Lending is critically important, there is very little information...more
In Parts I and II I explained the devastating impact of the new CRA Rule and what the underlying reasons for that adverse impact are. In Part III I will touch upon what banks are most significantly impacted by the new Rule....more
This is our third blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more
In my previous email I explained the devastating impact of the new CRA Rule on the percentage of banks receiving a less than satisfactory CRA Performance Rating. The data in Table 32 within the new Rule demonstrate that if...more
This is our second blog post on the final rule issued on October 24, 2023 by the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency...more
The LSTA has regularly prepared and updated the LSTA Regulatory Guidance: U.S. Sanctions Issues in Lending Transactions (the “LSTA Guidance”). The LSTA Guidance contains a comprehensive review of sanctions, including...more
Introduction - On 22 September 2022, we published Growing Trend of Revenue Based Financing and its Legal Implications, which described revenue-based financing (RBF) and its growing popularity for use as an alternative...more
State legislatures in Georgia and Rhode Island recently amended their lending and licensing laws. The following are the noteworthy updates: Georgia - - HB 891 creates an exception from licensure under the Georgia...more
On May 4, the Connecticut Department of Banking issued a temporary cease and desist order directing a peer-to-peer lending platform that connected borrowers with third-party lenders to cease its lending-related activities on...more
Wyoming and Maine recently amended their laws related to licensure requirements for consumer lending: - In July, Wyoming adopted House Bill 0008 (HB 0008), which amends provisions of the Wyoming Uniform Consumer Credit...more
Omnibus accounts for payment systems operators and prefunding accounts: BoE update - The Bank of England (BoE) has updated its webpage on payment and settlement to add the following new sections to the information provided in...more
The U.S. Court of Appeals, Second Circuit has ruled that an online tribal lender must comply with state interest rate and licensing laws, allowing a pair of borrowers to move forward with their suit against tribal officials....more
After making headlines with its controversial arbitration rule, the embattled Consumer Financial Protection Bureau (CFPB or Bureau) released its rulemaking agenda for the rest of the year, putting financial services companies...more