Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

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Federal Reserve Bank of Cleveland Reports on Online Small Business Lending Focus Groups

The Federal Reserve Bank of Cleveland recently issued a special report on the results of online focus groups it conducted with the Federal Reserve Board “to better understand small businesses’ perceptions of online...more

9/4/2015 - Borrowers Consumer Lenders Cyber Threats Cybersecurity Data Breach Data Security Federal Reserve Financial Sector Financial Services Industry Loans Online Marketplace Lending Privacy Concerns Request For Information Small Business

CFPB lawsuit against pension advance companies could have broader implications

A new lawsuit, filed by the CFPB and the New York Department of Financial Services(NY DFS) in a California federal court against two pension advance companies and three of the companies’ individual managers, again...more

8/25/2015 - Advances CFPB Financial Sector Financial Services Industry Investors Loans NYDFS Pensions Popular

Treasury Department Extends Comment Period for Online Marketplace Lending Information Request

The U.S. Department of the Treasury has extended the deadline for submitting comments in response to its request for information (RFI) regarding online marketplace lending. Initially set to close on August 31, 2015, the...more

8/20/2015 - Consumer Lenders Financial Regulatory Reform Financial Services Industry Internet Lenders Request For Information U.S. Treasury

Treasury Department Seeks Information on Online Marketplace Lending

The U.S. Department of the Treasury has issued a request for information (RFI) regarding online marketplace lending. The RFI reflects the Treasury Department’s recognition that online marketplace lending “is a rapidly...more

7/21/2015 - CFPB Dodd-Frank Financial Services Industry Lending Loans Online Marketplace Lending Popular Request For Information U.S. Treasury

OCC Report Identifies Risks to Banks, Sets Supervisory Priorities

A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more

7/13/2015 - Banking Regulators Banking Sector Banks BSA/AML Chief Compliance Officers Compliance Depository Institutions OCC Risk Assessment Supervision

32 Democratic senators call for strong payday lending rules

A group of 32 Democratic U.S. senators sent a letter to Director Cordray last week regarding the CFPB’s efforts to address payday lending in which they urged him “to issue the strongest possible rules to end the damaging...more

6/9/2015 - Ability-to-Repay CFPB Legislative Agendas NPRM Payday Loans Richard Cordray

Second Circuit Ruling Undermines National Bank Act Preemption of State Usury Laws for Loans Transferred to Non-Banks

The U.S. Court of Appeals for the Second Circuit ruled last week that a purchaser of charged-off debts from a national bank was not entitled to assert the preemption of state usury laws available to national banks under...more

6/1/2015 - Banking Sector FDCPA Financial Institutions Midland Funding National Bank Act Preemption Usury

The CFPB’s contemplated payday/title/high-cost lending proposals: our thoughts on collection practice limits

This is the last of a series of blog posts in which we share our reactions to the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our...more

4/7/2015 - Ability-to-Repay CFPB Consumer Financial Products Consumer Lenders Debt Collection Payday Loans Proposed Regulation Title Loans

Some issues for “longer-term” loans under the CFPB’s contemplated payday/title/high-cost lending proposals

In this blog post, we share our thoughts on the 36% “all-in” rate trigger and restrictions for loans considered to be “longer-term” under the CFPB’s contemplated proposals taking aim at payday (and other small-dollar,...more

4/6/2015 - Ability-to-Repay CFPB Consumer Financial Products Consumer Lenders Payday Loans Proposed Regulation Title Loans

Some issues for “short-term” loans under the CFPB’s contemplated payday/title/high-cost lending proposals

In this blog post, we share our thoughts on how the CFPB’s contemplated proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”) will impact “short-term” Covered Loans and the flaws we see in...more

4/3/2015 - CFPB Consumer Financial Products Consumer Lenders Payday Loans Proposed Regulation Title Loans

The CFPB’s contemplated payday/title/high-cost lending proposals: our initial reactions

Last Friday, we posted a summary of the contemplated CFPB proposals taking aim at payday (and other small-dollar, high-rate) loans (“Covered Loans”). In this blog post, we share our thoughts on the CFPB’s grounds for the...more

4/2/2015 - CFPB Consumer Financial Products Consumer Lenders Dodd-Frank Payday Loans Popular Proposed Regulation Title Loans

CFPB shows its hand on payday (and title and longer-term high-rate) lending

The CFPB has moved a step closer to issuing payday loan rules by releasing a press release, factsheet and outline of the proposals it is considering in preparation for convening a small business review panel required by the...more

3/30/2015 - ACH Payments CFPB Consumer Lenders Dodd-Frank Payday Loans Title Loans

DOJ Announces Two More ‘Operation Choke Point’ Settlements

With the recent announcement by the U.S. Department of Justice (DOJ) that it had settled separate lawsuits against two small banks charged with facilitating consumer fraud through their relationships with third-party payment...more

3/23/2015 - Bank Fraud Bank Secrecy Act Banks Choke Point Criminal Prosecution DOJ Enforcement Actions Popular

OCC Updated Examiner Guidance Includes New Overdraft Protection Program Requirements

In updated examiner guidance and examination procedures issued last week, the Office of the Comptroller of the Currency (OCC) directs its examiners to assess whether the overdraft protection and other deposit-related consumer...more

2/20/2015 - Banking Sector Banks Depository Institutions Guidance Update OCC Overdraft Fees Supervision

Texas Federal Court Rejects Challenge to ‘No Credit Card Surcharge’ Law

A federal district court in Texas has dismissed a lawsuit brought by several merchants challenging the constitutionality of a state law that prohibits merchants from imposing a surcharge on credit card purchases. In Rowell v....more

2/11/2015 - Credit Card Surcharges Credit Cards Debit and Credit Card Transactions Dismissals Due Process First Amendment Retailers

FTC Announces Settlement of First Actions against Auto Title Lenders

The Federal Trade Commission recently announced that it has entered into proposed settlements with two auto title lenders that were charged with deceptive advertising in violation of Section 5 of the FTC Act and the Truth in...more

2/5/2015 - Advertising Automotive Industry Automotive Loans Civil Monetary Penalty Enforcement Actions False Advertising FTC Regulation Z Settlement TILA

FDIC Eases Stance on Bank Relationships with ‘Risky’ Businesses - But Not the Time for Complacency on Compliance

The Federal Deposit Insurance Corporation (FDIC) has issued a “Statement on Providing Banking Services” in which it “encourages institutions to take a risk-based approach in assessing individual customer relationships rather...more

2/2/2015 - Banking Sector Banks FDIC New Guidance TPPPs

FTC Announces Settlement with Online Payday Lenders

The Federal Trade Commission recently announced a settlement with two online payday lenders to resolve charges that they violated the FTC Act, the Truth in Lending Act (TILA), and the Electronic Fund Transfer Act (EFTA). The...more

1/27/2015 - EFTA FTC FTCA Payday Loans Settlement TILA

CFPB encourages comments on prepaid card proposal

Kelly Cochran, CFPB Assistant Director for Regulations, addressed the CFPB’s prepaid card rulemaking in a January 12 presentation to the American Bar Association Consumer Financial Services Committee in New Orleans. She...more

1/13/2015 - American Bar Association Banking Sector CFPB Consumer Financial Products Prepaid Payment Products Proposed Regulation

FTC Increases Exclusionary Limit for Certain Door-to-Door Sales

The Federal Trade Commission has adopted a final rule amending its Cooling-Off Rule to exclude from the Rule’s coverage door-to-door sales of consumer goods or services with a purchase price of $130 or more that are made at...more

1/9/2015 - Amended Regulation Cooling-Off Rule Final Rules FTC

Petitioner Opposes NY Regulator’s Motion To Dismiss Lawsuit Seeking Access to Database of Alleged Illegal Payday Lenders

The consumer financial services attorney (the petitioner) who sued the New York State Department of Financial Services (DFS) and its superintendent, Benjamin Lawsky, to obtain access to DFS’s database of alleged illegal...more

12/17/2014 - Consumer Lenders FOIA Motion to Dismiss Payday Loans

CFPB Director Cordray Issues Warning to Bankers

Director Cordray’s remarks to the Clearing House Thursday should unsettle bankers and payday lenders alike. In his talk, Director Cordray challenged bankers to bow to the inevitable. He suggested that sooner, rather than...more

11/24/2014 - Banking Sector Banks CFPB Choke Point EFTA NACHA Payday Loans Popular Richard Cordray TILA

CFPB Proposes Sweeping Changes for Prepaid Cards

The Consumer Financial Protection Bureau has issued an 870-page proposal for prepaid cards (including 156 pages of actual proposed rules) that mandates new disclosures, error resolution procedures, consumer liability limits...more

11/14/2014 - CFPB Prepaid Payment Products Proposed Regulation

N.Y. Department of Financial Services Sued for Access to Documents Pertaining to Database of Alleged Illegal Payday Lenders

A consumer financial services attorney (the petitioner) recently filed a petition in New York state court against the New York State Department of Financial Services (DFS) and its superintendent, Benjamin Lawsky. The lawsuit...more

10/14/2014 - Banks Blacklist Department of Financial Services FOIA Payday Loans

CFSA Presses Its Case against ‘Operation Choke Point’

The Community Financial Services Association of America (CFSA), the national trade association for the payday lending industry, has filed a memorandum in support of its previously filed lawsuit against the agencies it accuses...more

10/9/2014 - Banks Choke Point Lenders Payday Loans

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