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Payday Lending Rule Loans

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2024 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

Earned Wage Access Products Are Not Loans, According to the AG of Montana

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On December 22, 2023, the Attorney General of Montana released an opinion (the “Opinion”) concluding that certain earned wage access (EWA) products are not “consumer loans” or “deferred deposit loans” under Montana law and do...more

Orrick, Herrington & Sutcliffe LLP

Montana AG opines that EWA products are not loans

On December 22, the Attorney General from the State of Montana opined that Earned Wage Access (EWA) products are not loans under a certain set of conditions. EWA products provide employees with fast access to cash by...more

Troutman Pepper

Montana AG Opines That Earned Wage Access Products Do Not Constitute Loans

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On December 22, Montana Attorney General Austin Knudsen issued an opinion on whether Earned Wage Access (EWA) products constitute either “consumer loans” under Montana Code § 32-5-102(2)(a) or “deferred deposit loans” under §...more

Alston & Bird

Payday Lending: A Juxtaposition of Recent CFPB Actions

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A&B ABstract: Three recent actions by the Consumer Financial Protection Bureau (“CFPB”), on consecutive days, highlights inconsistencies in the CFPB’s current approach to payday lending....more

Vedder Price

Pay Day Lending: Here Come the Banks!

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In a recent interview, Comptroller of the Currency Joseph Otting, announced the OCC’s plan to “clarify” its support of bank-offered deposit advance products. “Deposit advance products” are typically defined as small-dollar,...more

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