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Disclosure Requirements › Ability-to-Repay

K&L Gates LLP

European Community Consumer Credit Protection Laws: Similarities and Differences in the United States for Non-Mortgage Credit

K&L Gates LLP on

Financial institutions that operate only in the United States (US) or only in the European Union (EU) might be excused for believing that they face unreasonable burdens under local consumer credit protection laws. Broadly...more

Bradley Arant Boult Cummings LLP

A Deeper Dive: The CFPB Short-Term Small- Dollar Lending Rule

Bradley Arant Boult Cummings LLP on

Introduction - By now you’ve likely heard that the Consumer Financial Protection Bureau (CFPB) has released a final small-dollar lending rule. The hallmark of the rule is the requirement That lenders make a reasonable...more

Ballard Spahr LLP

Guidance from the OCC to banks regarding higher loan-to-value loan programs

Ballard Spahr LLP on

On August 21, 2017, the Office of the Comptroller of the Currency (OCC) published Bulletin 2017-28 regarding higher-loan-to-value (LTV) lending programs (the “Bulletin”). Recognizing the need for further revitalization...more

Kelley Drye & Warren LLP

CFPB Proposes Rule on Prepaid Products to Extend Certain Credit Requirements and Mandate Disclosures

Kelley Drye & Warren LLP on

The Consumer Financial Protection Bureau released last week a proposed rule that would impose an array of new requirements on prepaid accounts. ...more

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