News & Analysis as of

Regulation Z

Kilpatrick

CFPB Shifts Course on Buy Now, Pay Later: Interpretive Rule Revoked, Legal Challenge Implications

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The Consumer Financial Protection Bureau (CFPB) recently announced a significant change in its approach to the burgeoning "buy now, pay later" (BNPL) market. The Bureau has announced plans to revoke its May 2024 interpretive...more

Ballard Spahr LLP

Senate adopts resolution to nullify CFPB overdraft rule

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The Senate on March 27 adopted a resolution that would nullify the CFPB’s overdraft rule. The Senate adopted S. J. Res. 18 by a vote of 52-48, with Sen. John Hawley, R-Mo., the only Republican voting against repeal....more

Ballard Spahr LLP

CFPB plans to revoke BNPL interpretive rule

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The CFPB intends to revoke its Buy Now, Pay Later interpretive rule, according to a status report and joint motion to stay filed by the Bureau and the Financial Technology Association (FTA) in a case brought by the FTA...more

Katten Muchin Rosenman LLP

RIP Overdraft Rule?

Last month, bills were introduced in the House and Senate to overturn the much-maligned CFPB overdraft rule. You can find our previous write-up on the rule here. The rule would redefine “finance charge” under Regulation Z to...more

Orrick, Herrington & Sutcliffe LLP

CFPB notifies court of its intent to revoke its Buy Now, Pay Later rule

On March 26, the CFPB filed a status report and joint motion to stay proceedings in a case challenging its Buy Now, Pay Later interpretive rule indicating that the Bureau intends to revoke the rule. As previously covered by...more

Goodwin

2024 Year in Review: Cards, Payments, and Consumer Banking

Goodwin on

We expect continued scrutiny by regulators on fees, including enforcement actions and rulemakings, with the caveat that the new administration could shift federal priorities away from this fee crackdown....more

Orrick, Herrington & Sutcliffe LLP

District court denies servicer’s motion to dismiss in RESPA case, rejects Loper argument

Recently, the U.S. District Court for the Eastern District of Missouri denied a motion to dismiss filed by a mortgage servicer (the defendant) which argued that the plaintiff’s claims were not cognizable after the Loper...more

McGlinchey Stafford

The Earned Wage Access Boom: Sixteen States Propose Legislation to Regulate These Types of Products

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Since the beginning of 2025, sixteen states have proposed legislation to regulate earned wage access. These states would join Kansas, Missouri, Nevada, South Carolina, and Wisconsin, which have each enacted legislation to...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks additional time to consider its position on “Buy Now, Pay Later” Interpretive Rule

On February 28, the U.S. District Court for the District of Columbia received a court filing from the CFPB and its Acting Director Russell Vought, indicating they intend to submit a status report by March 31 on whether the...more

Orrick, Herrington & Sutcliffe LLP

Banking and business groups ask district court to vacate CFPB’s Credit Card Late Fees Rule

On February 20, several business groups and trade associations filed a motion for summary judgment in the U.S. District Court for the Northern District of Texas in their lawsuit seeking to vacate the CFPB’s final rule...more

Orrick, Herrington & Sutcliffe LLP

CFPB dismisses five enforcement actions voluntarily

On February 27, the CFPB voluntarily dismissed, with prejudice, five additional enforcement actions it filed during the Biden administration: All enforcement actions were filed in federal courts, as opposed to using...more

Orrick, Herrington & Sutcliffe LLP

District court allows CFPB to withdraw its amicus brief, but requires it to remain on docket

On February 20, the U.S. District Court for the Southern District of New Jersey granted the CFPB’s motion to withdraw its amicus brief, but denied the Bureau’s request to strike the brief from the record. The CFPB submitted...more

Hudson Cook, LLP

CFPB Bites of the Month - January 2025 - June in January with the CFPB

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In this month's article, we share some of our top "bites" covered during the January 2025 webinar....more

Morrison & Foerster LLP

FinReg Currents - Week 5

On February 18, 2025, President Trump signed an Executive Order designed to reduce the power of federal independent agencies by bringing them under the purview of the White House. The Executive Order provides that it applies...more

Ballard Spahr LLP

CFPB revokes EWA advisory opinion

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The CFPB rescinded an advisory opinion that had described how one particular type of “earned wage” product did not involve the offering or extension of “credit” as that term is defined in the Truth in Lending Act and...more

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Mortgage

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2024 applicable to the mortgage industry. There was also a flurry of last-minute action by the CFPB in the mortgage space in the waning days of the Biden...more

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Credit Cards

Hudson Cook, LLP on

In this article, we share a timeline of our monthly "bites" for 2024 applicable to the credit card industry. The year saw the CFPB give a fair amount of attention to credit card products, with a focus on pricing....more

Orrick, Herrington & Sutcliffe LLP

CFPB publishes CARD Act-mandated request for information

On January 17, the CFPB published in the Federal Register a Request for Information (RFI) about a number of aspects of the consumer credit card market, as mandated by the CARD Act. The RFI seeks public input to shape the...more

Orrick, Herrington & Sutcliffe LLP

CFPB rescinds previous opinion regarding how one EWA product was not a “loan”

On January 15, the CFPB issued an advisory opinion rescinding its 2020 advisory opinion on earned wage access (EWA) products. As previously covered by InfoBytes, the CFPB’s 2020 advisory opinion stated that a certain EWA...more

Ballard Spahr LLP

Home equity contracts: The CFPB weighs in

Ballard Spahr LLP on

If there was any doubt about how the Consumer Financial Protection Bureau (“CFPB”) (under current leadership) feels about what it calls “home equity contracts” (also known as shared appreciation agreements, shared equity...more

Mayer Brown

CFPB Takes a Stance on Home Equity Contracts

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On January 15, 2025, the Consumer Financial Protection Bureau (“CPFB” or the “Bureau”) took three coordinated actions related to home equity contracts (also referred to as “home equity investments,” “home equity agreements,”...more

Troutman Pepper Locke

CFPB Rescinds 2020 Advisory Opinion on Earned Wage Access Products

Troutman Pepper Locke on

As part of a flurry of last minute regulatory activity by the Biden administration’s Consumer Financial Protection Bureau (CFPB or Bureau), on January 15, the CFPB published an advisory opinion in the Federal Register...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Warning on Risks of Home Equity Contracts, Takes Legal Action to Ensure Compliance with TILA

On January 17, 2024, the Consumer Financial Protection Bureau (CFPB) issued a report, consumer advisory, and filed an amicus brief addressing the risks associated with home equity contracts (HECs)—financial products often...more

Goodwin

CFPB Sues Manufactured Home Financing Company in Relation to Allegedly Risky Loans

Goodwin on

The Consu​​​​​​​mer Financial Protection Bureau (“CFPB”) filed a complaint against a manufactured home loan company (the “Company”) on January 6, 2025, alleging that it originates loans that borrowers are unlikely to be able...more

Mayer Brown

Regulatory Clouds on the Horizon for Solar Financing? Programs Face Headwinds, but the Future Still Looks Bright

Mayer Brown on

At A Glance - Coming off a period of rapid growth, the residential solar financing industry has begun to face increased pressures from aggressive compliance positions taken by regulators and consumer advocacy organizations....more

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