Consumer Finance Monitor Podcast Episode: How the CFPB Is Using Interpretive Rules to Expand Regulatory Requirements for Innovative Consumer Financial Products; Part Two: Earned Wage Access
Navigating the CFPB's Controversial Interpretive Rule on BNPL Products — The Consumer Finance Podcast
Consumer Finance Monitor Podcast Episode: Buy Now, Pay Later – Evolution, Regulation, and What You Need to Know about the CFPB Interpretive Rule Effective July 30
CFPB's New Interpretive Rule: Buy Now, Pay Later as Credit Cards — The Consumer Finance Podcast and Payments Pros Podcast
An In-Depth Analysis of the CFPB's Proposed Overdraft Rule — Payments Pros – The Payments Law Podcast
An In-Depth Analysis of the CFPB’s Proposed Overdraft Rule - The Consumer Finance Podcast
Exploring the Future of Open Banking: A Discussion on CFPB's 1033 Proposed Rule – Crossover Episode With Regulatory Oversight Podcast – The Consumer Finance Podcast
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
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
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
This week, New York became the latest state to introduce legislation aimed at regulating Earned Wage Access (EWA) services. Assembly Bill 258 titled — “An Act to Amend the Banking Law, in Relation to Providing for Income...more
On December 30, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that may dramatically change the way that certain large financial institutions offer overdraft services to consumers. Under the...more
What Happened? President Biden has proclaimed January 9, 2025, a federal holiday for the state funeral of former President Jimmy Carter; as a result, Federal government agencies and departments will be closed that day. Is...more
On December 12, 2024, the Consumer Financial Protection Bureau (CFPB) announced its final rule, redefining overdraft fees as finance charges in order to limit overdraft fees. The final rule seeks to regulate how overdraft...more
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule identifying Buy Now, Pay Later Lenders (BNPL Lenders or Lenders) as “card issuers” or “creditors” for the purposes of Regulation Z,...more
The United States is a big melting pot of cultures, ethnicities, and languages. This diversity is great for business, but if you are advertising that your business speaks "Spanish" or that your business can assist customers...more
On September 18, the CFPB issued a set of Frequently Asked Questions (FAQs) related to Buy Now, Pay Later (BNPL) products. These FAQs follow the CFPB's release of the 2024 BNPL Interpretive Rule (Interpretive Rule), which...more
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
In an unusual move, the CFPB is coming to the defense of a bank being accused of failing to provide repayment disclosures to a borrower....more
On June 4, the Fed published a request for comment on a proposal to extend the “Recordkeeping and Disclosure Requirements Associated with CFPB’s Regulation Z” for three years without revision. According to the notice, the...more
The Consumer Financial Protection Bureau's interpretative rule provides that traditional "Buy Now, Pay Later" (BNPL) products – closed-end loans that do not have a finance charge and are repaid in four installments – are...more
Point-of-sale financing arrangements payable in four or fewer interest-free installments, known as buy now, pay later (BNPL) arrangements, have soared since their initial breakthrough during the pandemic. Unlike conventional...more
In furtherance of the Biden Administration’s “junk fee” agenda, on January 17, 2024, the Consumer Financial Protection Bureau issued its proposed rule to amend Regulations E and Z to regulate overdraft services provided by...more
On April 11, the U.S. Court of Appeals for the Third Circuit upheld the dismissal of a putative class action suit claiming a national bank’s failure to itemize fees in its credit card renewal notices violated TILA and...more
The retail installment sales contracts used by auto dealerships include disclosures related to GAP insurance and other debt cancellation products that are required under the federal Truth in Lending Act in order for the...more
In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more
On July 23, 2020, the New York legislature passed A10118A/S5470B requiring disclosures in various commercial financing transactions, including loans, merchant cash advances ("MCA"), and factoring transactions (the "Disclosure...more
The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more
On December 11, 2019, PayPal, Inc. (PayPal) filed suit against the Consumer Financial Protection Bureau (CFPB) in the District of Columbia, challenging the CFPB’s Prepaid Accounts Under the Electronic Fund Transfer Act...more
The CFPB has issued its annual report on TILA, EFTA, and the CARD Act which covers activity in 2016 and 2017. The report provides brief summaries of the 2016 and 2017 enforcement actions brought by the CFPB and other federal...more
After several years of rulemaking, amendments, and delays, the CFPB’s Prepaid Rule (the “Rule”) is finally set to take effect on April 1, 2019. ...more
The CFPB recently released a revised version of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October...more