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Truth in Lending Act (TILA) NYDFS

Venable LLP

New York Commercial Financing Disclosure Requirements

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Providers of commercial financing that are subject to the New York State Commercial Finance Disclosure Law (CFDL) must provide disclosures to potential recipients of commercial financing at the time a specific offer of...more

Buchalter

NY DFS Publishes Final Regulation Implementing Article 8, New York State’s Commercial Finance Disclosure Law

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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

Ballard Spahr LLP

New York Department of Financial Services issues final regulations for consumer-like disclosures for commercial financing

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The New York Department of Financial Services (DFS) has issued final regulations implementing the state’s Commercial Finance Disclosure Law (CFDL) which requires consumer-like disclosures for “commercial financing”...more

Pillsbury Winthrop Shaw Pittman LLP

New York Finalizes Disclosure Requirements for Commercial Financing Transactions

New York has joined California and several other states in finalizing regulations requiring consumer-style disclosures for broad categories of commercial financing transactions....more

Ballard Spahr LLP

CFPB makes preliminary determinations that Truth in Lending Act does not preempt New York, California, Utah, and Virginia...

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In a notice of “Intent to Make Preemption Determination under the Truth in Lending Act (Regulation Z),” the CFPB announced that it is seeking comments on its preliminary determinations that the Truth in Lending Act (TILA)...more

Miles & Stockbridge P.C.

State Commercial Finance Disclosure Law Popularity Growing: Truth-in-Lending Type Disclosures in Commercial Loans

We reported last year on New York’s newly enacted commercial finance disclosure law and the legislature’s quick pivot thereafter, expanding the law’s reach to all loans up to $2,500,000 - a change from the previous limitation...more

Troutman Pepper

NYDFS Publishes Notice of Proposed Regulation for Commercial Financing Disclosures

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On October 20, the New York Department of Financial Services (NYDFS) published a notice in the New York State Register announcing that it has issued a proposed regulation to implement S 5470-B, which requires disclosures for...more

Bradley Arant Boult Cummings LLP

New York DFS Proposes Regulation to Implement TILA-Like Requirements on Small Business Loans

On September 21, 2021, New York’s Department of Financial Services (DFS) announced proposed regulations that clarify the small business Truth in Lending disclosure requirements that go into effect on January 1, 2022. The...more

Womble Bond Dickinson

CFPB Issues Advisory Opinion on Earned Wage Access Programs

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CFPB issued an advisory opinion on Earned Wage Access (EWA) on Monday afternoon. We’ve written about earned wage access products before as well as state legislative initiatives to regulate them. The new federal guidance...more

Manatt, Phelps & Phillips, LLP

New York Legislature Passes Bill Requiring Commercial Finance Disclosures

New York may soon be joining California in requiring consumer-like disclosures on commercial financing transactions. On July 23, 2020, the New York State legislature passed SB 5470 (S.5470/A.10118-A), which closely follows...more

Hudson Cook, LLP

New York Passes Small Business Finance Disclosure Law

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On July 23, 2020, the New York legislature passed A10118A/S5470B requiring disclosures in various commercial financing transactions, including loans, merchant cash advances ("MCA"), and factoring transactions (the "Disclosure...more

Womble Bond Dickinson

Wage Advance Products Draw First Consumer Class Action Lawsuits

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The legal uncertainties that surround wage advance products continue to boil and bubble. We’ve previously written about legal issues these products raise, the New York Department of Financial Services (“NYDFS”) investigation...more

Goodwin

Financial Services Weekly News - March 2017 #3

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

Morrison & Foerster LLP

Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

Manatt, Phelps & Phillips, LLP

First State Regulator Case Under Dodd-Frank Yields $12M Deal in New York

Why it matters - The first case brought by a state regulator under Section 1042 of the Dodd-Frank Wall Street Reform and Consumer Protection Act resulted in a consent judgment, with an auto lender agreeing to pay up to...more

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