News & Analysis as of

Regulation Z

CFPB Spring 2017 Supervisory Highlights focuses on mortgage origination/servicing, student loan servicing deficiencies, service...

by Ballard Spahr LLP on

The CFPB’s newly-released Spring 2017 edition of Supervisory Highlights covers supervisory activities generally completed between September and December 2016. The report indicates that supervisory resolutions resulted in...more

Mobile Wallets and Tokenization: Banks are Catching On

by Bryan Cave on

On April 20, 2017, the American Banker reported that U.S. Bank’s new high-end credit card features an interesting differentiator from the high-end cards recently introduced by other large credit card issuers. U.S. Bank’s new...more

New York Codifies Definition of Consummation Facilitating TRID Compliance

by Ballard Spahr LLP on

The New York Senate has approved Bill 982, which amends state law to expressly allow for execution of a mortgage loan by electronic signature. In connection with this amendment, the term “consummation of a mortgage loan” also...more

Financial Services Weekly News - March 2017 #3

by Goodwin on

Editor's Note - The Return of Glass-Steagall? On March 13, Federal Deposit Insurance Corporation Vice Chairman Thomas M. Hoenig made a speech to the Institute of International Bankers Annual Washington Conference...more

CFPB Proposes to Delay Prepaid Rule Effective Date

On October 5, 2016, the Consumer Financial Protection Bureau (the Bureau or CFPB) issued its final rule to extend certain federal consumer protections to the prepaid market. As previously reported, the rule extends Regulation...more

CFPB and Virginia AG settle claims against pawnbroker for alleged TILA/CFPA/VA law violations

by Ballard Spahr LLP on

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

Takeaways: Consumer Payments in 2017

Regulatory Developments and Prospects for Consumer Gift Cards, Prepaid Cards, and Other Consumer Electronic Payment Methods - Kilpatrick Townsend Partner Christina Gattuso and Counsel Eamonn Moran recently provided an...more

ABA highlights error in cost of credit calculation method used in CFPB’s proposed payday loan rule

by Ballard Spahr LLP on

At the meeting earlier this month of the American Bar Association’s Consumer Financial Services Committee in Carlsbad, CA, attention was given to an issue highlighted by the American Bankers Association in the comment letter...more

CFPB announces annual adjustments to HMDA/TILA asset-size exemption thresholds

by Ballard Spahr LLP on

The CFPB has announced annual adjustments to two asset-size exemption thresholds. First, the CFPB has made no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million. ...more

CFPB sues four pawnbrokers for alleged TILA and CFPA violations

by Ballard Spahr LLP on

The CFPB announced that it has sued four Virginia-based pawnbrokers in lawsuits filed in a Virginia federal district court for alleged violations of the Truth in Lending Act and the Consumer Financial Protection Act in...more

CFPB settles with military financing company for alleged TILA/EFTA disclosure violations

by Ballard Spahr LLP on

The CFPB announced that it has entered into a consent order with Military Credit Services, LLC, a company providing revolving credit to military consumers, to settle allegations that the company’s open-end credit agreements...more

Second Circuit Finds No Standing, Affirms Summary Judgment on TILA Claims

by Goodwin on

On November 23, 2016, the Second Circuit issued its opinion in Strubel v. Comenity Bank, a putative Truth in Lending Act (TILA) class action with both standing and substantive TILA implications. In Strubel, the plaintiff...more

CFPB amends commentary on adjustments to exemption thresholds; makes no changes to 2017 thresholds

by Ballard Spahr LLP on

The CFPB has adopted changes to its Reg Z commentary to memorialize the calculation methods used each year to adjust the thresholds for exempt consumer credit transactions and for transactions exempt from the special...more

CFPB files lawsuit against pawnbroker for alleged TILA and CFPA violations

by Ballard Spahr LLP on

The CFPB announced that it filed a lawsuit in a Virginia federal district court against B&B Pawnbrokers, Inc., for alleged violations of the Truth in Lending Act and the Consumer Financial Protection Act in connection with...more

CFPB issues Fall 2016 Supervisory Highlights

by Ballard Spahr LLP on

In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more

What To Know About CFPB's New Prepaid Card Rule

by Morrison & Foerster LLP on

The Consumer Financial Protection Bureau issued its final rule to amend provisions of Regulation E and Regulation Z to further regulate prepaid card products, or “prepaid accounts.” As discussed below, the rule generally...more

US Consumer Financial Protection Bureau Issues Final Rule to Protect Prepaid Account Users

by Shearman & Sterling LLP on

The CFPB issued a final rule that applies federal consumer protections under Regulations E and Z for prepaid account users for the first time. Prepaid accounts may be loaded with funds by a consumer or by a third party, such...more

The Prepaid Rule is Finally Here

Last week, the CFPB issued its long-awaited final rule amending Regulation E (Electronic Funds Transfer Act) and Regulation Z (Truth in Lending Act) to create regulations for prepaid financial products (Prepaid Rule). The...more

FTC Targets Auto Dealers, Alleges Deceptive Financing Practices

by Ballard Spahr LLP on

The Federal Trade Commission (FTC) has filed an action against nine auto dealerships and their individual owners in a California federal court that the FTC described as its "first action against an auto dealer for 'yo-yo'...more

The CFPB’s Final Prepaid Account Rule

by Davis Wright Tremaine LLP on

On October 13, the DWT Payments team briefed the Consumer Working Group of the Financial Services Roundtable (FSR) on the CFPB’s final prepaid account rule. The presentation focused on the following topics: - Scope of...more

CFPB Issues Long-Awaited Prepaid Account Products Final Rule

On October 5, 2016, the Consumer Financial Protection Bureau (the Bureau or the CFPB) issued its final rule to extend certain federal consumer protections to the prepaid market.1 Specifically, the rule extends Regulation E...more

CFPB finalizes sweeping expansion of prepaid account regulations

by Ballard Spahr LLP on

The CFPB has issued its long-anticipated final rule for general purpose prepaid accounts.  As expected, the new regulations expand the products covered by Regulation E, introduce significant new disclosure requirements,...more

CFPB Finalizes Sweeping Expansion of Prepaid Account Regulations

by Ballard Spahr LLP on

The Consumer Financial Protection Bureau (CFPB) has issued its long-anticipated final rule for general purpose prepaid accounts. As expected, the new regulations expand the products covered by Regulation E, introduce...more

DoD Publishes Guidance on MLA Amendments

With the July 2015 amendments to the Military Lending Act (MLA) set to take effect on October 3, the Department of Defense (DoD) published an interpretive rule to help financial institutions achieve compliance with the...more

Nutter Bank Report, August 2016

FDIC Proposes Expansion of Third-Party Lending Examinations - The FDIC has extended the public comment period on proposed examination guidance that would significantly expand the scope of examinations of banks’...more

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