Jeremy T. Rosenblum

Jeremy T. Rosenblum

Ballard Spahr LLP

Contact  |  View Bio  |  RSS

Latest Posts › Payday Loans

Share:

Installment Lender Using Bank Partner Model Needs Maryland License, Court of Appeals Rules

The Maryland Court of Appeals, the state's highest court, in CashCall, Inc. et al. v. Maryland Commissioner of Financial Regulation, recently affirmed the judgment of the Court of Special Appeals (MCSA) directing CashCall to...more

7/15/2016 - Banking Sector Banks CashCall Consumer Financial Products Consumer Lenders Financial Services Industry Interest Rates Licensing Rules Loan Origination Funds Madden v Midland Funding Online Marketplace Lending Payday Loans Preemption Usury

CFPB issues proposed payday/auto title/high-rate installment loan rule

As expected, the CFPB issued its proposed payday loan rule, in a release running 1,334 pages. The CFPB also issued a fact sheet summarizing the proposal. Once we complete our initial review of the proposal, we will issue a...more

6/3/2016 - Ability-to-Repay Automotive Loans CFPB Installment Agreements NCUA Payday Loans Proposed Regulation SBREFA

The CFPB’s auto title loan report: last step to a payday/title loan proposal?

The CFPB has issued a new report entitled “Single-Payment Vehicle Title Lending,” summarizing data on single-payment auto title loans. The latest report is the fourth report issued by the CFPB in connection with its...more

5/20/2016 - Automotive Industry Automotive Loans Banking Sector CFPB Consumer Financial Products Consumer Lenders Payday Loans Rulemaking Process Title Loans

The CFPB’s report on online payday loan payments: setting the stage for limits on collection practices?

The CFPB has issued a new report entitled “Online Payday Loan Payments,” summarizing data on returns of ACH payments made by bank customers to repay certain online payday loans. The latest report is the third report issued...more

4/25/2016 - ACH Payments CFPB Online Payments Payday Loans

Owner of Payday Lenders, Attorney Hit with Federal Criminal Indictment

A man alleged to be the owner and operator of a group of payday-lending companies and an attorney alleged to have submitted false affidavits and structured sham arrangements have been indicted by a federal grand jury in New...more

2/15/2016 - Banking Sector Indictments Native American Issues Payday Loans Regulation Z RICO Sovereign Immunity Tribal Loans Truth in Lending Act (TILA)

CA federal court refuses to dismiss CFPB lawsuit against payday lending companies alleging UDAAP violations based on state law...

A federal district court has refused to dismiss the lawsuit filed by the CFPB in December 2013 against CashCall, several related companies and their principal, which asserted UDAAP violations based on the defendants’ efforts...more

1/6/2016 - CashCall CFPA CFPB Debt Collection Payday Loans Tribal Loans UDAAP Usury

Commerce Clause Does Not Prevent Minnesota from Regulating Internet Loans Made to State Residents, Minnesota Supreme Court Rules

The Minnesota Supreme Court has ruled that the Commerce Clause of the U.S. Constitution does not preclude Minnesota from applying its payday lending law to loans consummated in Delaware that are made to Minnesota residents...more

10/30/2015 - Banking Sector Commerce Clause Consumer Financial Products Consumer Lenders Financial Institutions Home State Exception Online Marketplace Lending Online Platforms Payday Loans Websites

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

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

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 FTC Act Payday Loans Settlement Truth in Lending Act (TILA)

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 Truth in Lending Act (TILA)

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

Pew’s Fourth Report Targets Online Payday Lending

The Pew Charitable Trusts has released the fourth report in its “Payday Lending in America” series. The new report examines issues with the online payday loan market and draws distinctions with the storefront-based payday...more

10/8/2014 - Internet Lenders Payday Loans

Second Circuit Issues Decision in Payday-Loan Regulatory Case

In a clash of competing sovereigns’ interests, the Second Circuit recently upheld, for now, the authority of the New York Department of Financial Services (DFS) to regulate online payday loans made by Indian tribal lenders to...more

10/6/2014 - Banks Consumer Financial Products Consumer Lenders NACHA Native American Issues Payday Loans Preliminary Injunctions Tribal Governments

New York Grand Jury Indicts 12 Online Payday Lenders and 3 Individuals

In a shot across the bow of online payday lenders who allegedly disregard state law where their borrowers reside, a New York County grand jury recently voted a criminal usury and conspiracy indictment against 12 companies...more

8/15/2014 - Conspiracies Grand Juries Lenders Payday Loans Usury

FDIC Withdraws List of ‘Risky’ Businesses

In an unexpected move earlier this week, the FDIC issued a Financial Institution Letter (FIL) announcing that it was withdrawing the list of “risky” merchant categories that was included in prior guidance on account...more

8/1/2014 - Choke Point Enforcement FDIC Money Transfer Payday Loans Strategic Enforcement Plan TPPPs

FDIC withdraws list of “risky” businesses alleged to be targeted in “Operation Choke Point”

In an unexpected move earlier this week, the FDIC issued a Financial Institution Letter announcing that it was withdrawing the list of “risky” merchant categories that was included in prior guidance on account relationships...more

8/1/2014 - Compliance Enforcement Enforcement Actions FDIC Money Transfer Payday Loans

Federal district court grants CFPB petition to enforce CIDs issued to tribal lenders

A California federal court recently issued an order granting the CFPB’s petition to enforce its civil investigative demands (CIDs) issued to three tribally-affiliated payday lenders. However, the court also granted the...more

7/29/2014 - CFPA CFPB CID Payday Loans Tribal Loans

House to hold hearings on “Operation Choke Point”

Two House committees have scheduled hearings this week on “Operation Choke Point,” the coordinated federal multiagency enforcement initiative targeting banks serving online payday lenders and other companies that have raised...more

7/15/2014 - Banks Choke Point Congressional Investigations & Hearings Enforcement Legislative Agendas Legislative Committees Payday Loans

61 Results
|
View per page
Page: of 3

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×