The Consumer Financial Protection Bureau's interpretative rule provides that traditional "Buy Now, Pay Later" (BNPL) products – closed-end loans that do not have a finance charge and are repaid in four installments – are...more
On June 30, 2023, the Indiana Department of Financial Institutions published Advisory Letter 2023-01, addressing the permissibility of e-lien fees not payable to the Indiana Bureau of Motor Vehicles. The publication was...more
Superintendent of Financial Services Adrienne A. Harris announced on February 1, 2023 that the New York State Department of Financial Services has adopted a final regulation relating to early disclosure requirements on...more
On June 9, 2022, the California Office of Administrative Law approved the Department of Financial Protection and Innovation’s final regulations implementing California’s first-of-its-kind commercial financing disclosure law....more
On June 9, 2022, the California Office of Administrative Law (OAL) approved the California Department of Financial Protection and Innovation’s (DFPI) final regulations requiring providers of commercial financing, including...more
A new year brings new compliance requirements for non-banks and fintechs conducting business in New York, including Merchant Cash Advance (MCA) companies. On December 23, 2020, New York Gov. Andrew Cuomo signed SB5470...more
The California Department of Financial Protection and Innovation (fka Department of Business Oversight) is one step closer to issuing final regulations that would impose new early disclosure requirements on covered commercial...more
The CFPB announced last week that it has entered into a consent order with Triton Management Group, Inc., a small-dollar lender, to settle the CFPB’s allegations that Triton had violated the Truth in Lending Act and the...more
The Federal Reserve Board announced that it had issued a Consent Order against Mid America Bank and Trust Company (Bank) for alleged deceptive marketing practices in violation of section 5 of the FTC Act related to balance...more
The CFPB and the Virginia Attorney General announced that they had entered into a proposed consent order with Woodbridge Coins and Jewelry Exchange, Inc., a Virginia-based pawnbroker, to settle a lawsuit filed in a Virginia...more
The Federal Trade Commission (FTC) has obtained a $1.3 billion judgment against the individual operator of several payday lenders and related servicing and marketing companies in a lawsuit filed in a Nevada federal district...more
On July 22, 2015, the Department of Defense (DOD) published sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more