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Ballard Spahr LLP

VA Proposes Rules for ARM Loans and Temporary Buydown Agreements

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The U.S. Department of Veterans Affairs (VA) recently proposed rules under its home loan guaranty program regarding adjustable rate mortgage (ARM) loans, hybrid ARM (h-ARM) loans and temporary buydown agreements. Comments are...more

Crunched Credit

Could We Bring It All Down?

Crunched Credit on

I’m going to tell you a story. This is the type of thing told around campfires designed to scare naïfs, who know too little, and PhDs who (think) they know too much. I don’t necessarily believe in the story, but it could be...more

Ballard Spahr LLP

CBA “checks the math” on recent CFPB credit card report finding large bank issuers charge higher interest rates than smaller...

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After targeting credit card late fees in its proposed rule, the CFPB has set its sights on further attacking credit card pricing through interest rates. The CFPB published a blog late last month stating that credit card...more

Ballard Spahr LLP

New CFPB credit card report finds large bank issuers are charging higher interest rates than smaller issuers

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In a new data spotlight issued last week, the Consumer Financial Protection Bureau (“CFPB”) found that interest rates charged on credit cards issued by large banks are higher than interest rates charged on credit cards issued...more

Troutman Pepper

Rhode Island and Minnesota Latest States with Bills Opting Out of Federal Banking Law Allowing Interest Rate Exportation

Troutman Pepper on

On February 12, ten Rhode Island senators introduced S 2275, a bill proposing to opt Rhode Island out of §§ 521-523 of the Depository Institutions Deregulation and Monetary Control Act (DIDMCA). On February 13, HF 3680 was...more

Ballard Spahr LLP

Rate Exportation Opt-Out and “Anti-Evasion” Bill Introduced in Washington D.C.

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District of Columbia Council Bill B 25-0609, which would opt out of Section 27 of the Federal Deposit Insurance Act (“FDIA”) with respect to loans made in the District of Columbia, was introduced in the District of Columbia...more

Orrick, Herrington & Sutcliffe LLP

Madden Progeny Update

The Second Circuit’s decision in Madden v. Midland Funding, LLC was announced in 2015. Since that time, there have been a number of cases brought based on the Second Circuit opinion, as well as recent regulatory proposals...more

Ballard Spahr LLP

House Financial Services Committee announces January hearings on CRA, “rent-a-bank schemes,” mobile payments

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The House Financial Services Committee has announced that it will hold the following hearings this month: On January 14, the Subcommittee on Consumer Protection and Financial Institutions will hold a hearing entitled, “The...more

Ballard Spahr LLP

Bill to impose 36% rate cap on consumer credit expected to be introduced

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According to an NPR report published last week, a group of lawmakers consisting of three Democratic Senators, one Democratic House member, and one Republican House member is expected to introduce House and Senate versions of...more

Ballard Spahr LLP

Republican lawmakers urge OCC to address Madden through rulemaking

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The Republican members of the House Financial Services Committee have sent a letter to Comptroller of the Currency Joseph Otting urging the OCC to make action to address the uncertainty created by Second Circuit’s Madden...more

Ballard Spahr LLP

California Financing Law Rate Cap Advances to Governor Newsom’s Desk

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On the last day of California’s 2019 legislative session, by a vote of 61 to 8, the California State Assembly overwhelmingly passed Senate Bill 539, the Fair Access to Credit Act. Governor Newsom has until October 13th to...more

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