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Treatment of Educational ISAs Under Federal and Select State Anti-Discrimination Statutes

In this paper, we consider whether educational income share agreements (“ISAs”) are subject to federal and state equal access and anti-discrimination laws. When an ISA provider (“Provider”) sets the terms of an ISA, the...more

CFPB Issues FAQs for the TRID Rule

The Consumer Financial Protection Bureau (CFPB) has posted a new compliance tool on its website - answers to frequently asked questions (FAQs) about the TILA-RESPA Integrated Disclosure Rule (“TRID Rule”). Apparently in...more

CFPB and New York Attorney General Announce Settlement with Retailer for Violations of TILA and CFPA

On January 16, 2019, the Consumer Financial Protection Bureau (CFPB) and the New York Attorney General announced a settlement with a retailer for alleged violations of the Consumer Financial Protection Act of 2010 (CFPA) and...more

CFPB Finalizes Rule Suspending Quarterly Submission of Credit Card Agreements

On April 15, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced a final rule (“Final Rule”) that suspends for one year the requirement under the Truth in Lending Act and implemented by Regulation Z that credit...more

Overview of the CFPB Prepaid Account Proposed Rule

On November 13, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule to regulate prepaid accounts (the “Proposed Rule”). The Proposed Rule follows the CFPB’s May 2012 advance notice of proposed...more

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