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 Popular 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 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

Lender Violated EFTA Prohibition on Conditioning Loans on Electronic Payments, Calif. Federal Court Rules

A California federal court recently ruled that a lender violated the Electronic Fund Transfer Act (EFTA) prohibition on “condition[ing] the extension of credit” on a borrower’s repayment “by means of preauthorized electronic...more

8/6/2014 - EFTA Electronic Fund Transfer Act FTC Loans

OCC and FDIC Follow Through on Threat To Kill Deposit Advance Loans

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have carried out their threats in their proposed guidance to kill deposit advance loans. On November 21, 2013, the two...more

12/2/2013 - Banks Deposit Advances FDIC Loans OCC

Pew Report on Payday Loans Makes Questionable Policy Recommendations

The Pew Charitable Trusts has released the third report in its “Payday Lending in America” series. The new report makes policy recommendations that are intended to apply to all small-dollar consumer cash loans (other than...more

11/5/2013 - Loans Payday Loans

Uncertainty Remains Under CFPB's Proposed Changes to Prohibition on Financing Credit Insurance Premiums

The CFPB has proposed changes to the Regulation Z prohibition on financing credit insurance premiums (Section 1026.36(i)) as part of several new proposed amendments to the mortgage rules it adopted in January 2013....more

7/2/2013 - CFPB Lenders Loan Originator Compensation Rule Loans Premiums Proposed Amendments Regulation Z

OCC and FDIC proposed guidance could effectively ban deposit advance loans

Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans. The Federal Reserve Board declined to join the OCC and FDIC and instead...more

4/30/2013 - CFPB Compliance Deposit Advances FDIC Loans OCC Proposed Regulation Underwriting

CFPB Expands Public Consumer Complaint Database

The Consumer Financial Protection Bureau has expanded its public Consumer Complaint Database to include complaints about mortgages, bank deposit products and services, student loans, and other consumer loans (which category...more

4/1/2013 - CFPB Consumer Complaint System Loans Mortgages Student Loans

A bad month for payday lenders

February was not a good month for payday lenders. As previously reported, on February 20, CFPB Director Cordray expressed pointed concerns about payday and short-term loan “debt traps” in a speech to the Consumer Advisory...more

3/1/2013 - Banks CFPB Consumer Lenders Lenders Loans Payday Loans Richard Cordray

Shoot first, question later?

In his recent post, Alan Kaplinsky rightly warned that recent remarks by Director Cordray strongly imply that payday and other short-term loan products may be in “the CFPB’s line of fire.” What bothers me is that, to my...more

3/1/2013 - Loans Payday Loans Richard Cordray

Pennsylvania Enacts Changes to Banking Laws

Significant changes to Pennsylvania banking laws will take effect on December 24, 2012, as a result of three bills, known as the “Banking Law Modernization Package,” signed into law by Governor Tom Corbett....more

12/19/2012 - Derivatives Dodd-Frank Loans Securities

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