News & Analysis as of

Loans Advisory Opinions

Davis Wright Tremaine LLP

CFPB Takes Aim at Earned Wage Access Products as Regulated Loans

The Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule that would extend Truth in Lending Act (TILA) and Regulation Z (Reg Z) compliance requirements to many existing earned wage access (EWA) products....more

Ballard Spahr LLP

CFPB comments on California proposal to supervise providers of earned wage access products

Ballard Spahr LLP on

The Consumer Financial Protection Bureau has sent a letter to the California Department of Financial Protection and Innovation (DFPI) commenting on the DFPI’s proposal that would require providers of “income-based advances”...more

Wiley Rein LLP

FEC Advisory Opinion Roundup: Contributor-Centric Analysis Appears Here to Stay

Wiley Rein LLP on

The Federal Election Commission (FEC) recently issued three noteworthy advisory opinions covering a variety of topics. These opinions are briefly summarized below. Contribution Processors: Advisory Opinion 2022-10...more

Mintz - Health Care Viewpoints

OIG Issues Favorable Opinion on Federally Qualified Health Center’s Smartphone Loan Program

On April 27, 2022, the Office of Inspector General (OIG) for the Department of Health and Human Services issued Advisory Opinion No. 22-08 (AO 22-08), which addresses an existing arrangement of a federally qualified health...more

Perkins Coie

Fintech Legal Report - October 2021

Perkins Coie on

Chopra Sworn in as CFPB Director On October 12, 2021, Rohit Chopra was sworn in as the CFPB Director. Acting Director David Uejio will leave his post but will remain at the CFPB as he awaits his likely confirmation to a fair...more

Saul Ewing LLP

The Consumer Financial Protection Bureau to Issue Advisory Opinions to Answer Interpretive Questions

Saul Ewing LLP on

The Consumer Financial Protection Bureau (CFPB) released its final Advisory Opinions Policy (AOP) on Monday, November 30, setting forth procedures to facilitate the submission of requests for advisory opinions from it by...more

Bryan Cave Leighton Paisner

FDIC Advisory Letter on Loan Participations

On November 6th, the FDIC issued an advisory letter discussing risk management practices that FDIC-supervised banks should implement with regards to purchased loans and loan participations. While the FDIC acknowledges the...more

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