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Regulation Z Proposed Rules Credit

Ballard Spahr LLP

NCLC Asks CFPB to Consider Residential Leases as Credit for Specific Purposes

Ballard Spahr LLP on

The National Consumer Law Center is asking the CFPB, by way of a petition, for rulemaking that is long on policy arguments but woefully short on legal support, as we note below, to define residential leases as “credit” under...more

Davis Wright Tremaine LLP

CFPB Takes Aim at Earned Wage Access Products as Regulated Loans

The Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule that would extend Truth in Lending Act (TILA) and Regulation Z (Reg Z) compliance requirements to many existing earned wage access (EWA) products....more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes Interpretive Rule Characterizing Earned Wage Access Products as Loans

On July 18, the CFPB proposed a new interpretive rule that would characterize earned wage access (“EWA”) products as extensions of credit and subject to the Truth in Lending Act and Regulation Z. Under the interpretive...more

Troutman Pepper

CFPB Says Earned Wage Access Products are Subject to the Truth in Lending Act

Troutman Pepper on

Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on

The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

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