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White House Executive Order Eliminates Disparate-Impact Liability Enforcement

On April 23, the White House issued an Executive Order entitled Restoring Equality of Opportunity and Meritocracy, directing federal agencies to “eliminate the use of disparate-impact liability in all contexts to the maximum...more

Ohio AG Sues Mortgage Lender for Illegal Broker Steering Scheme

On April 17, Ohio Attorney General Dave Yost announced that the state has filed a lawsuit against a wholesale mortgage lender, alleging that the company engaged in a statewide scheme to mislead borrowers and inflate mortgage...more

CFPB Plans Limited Enforcement of Payday Lending Rule

On March 28, the CFPB announced that it will not prioritize enforcement or supervision of the remaining provisions of its Payday, Vehicle Title, and Certain High-Cost Installment Loans Regulation, which were set to take...more

Second Circuit Upholds Reverse Redlining Verdict Against Mortgage Lender

On February 14, a divided Second Circuit panel upheld a 2016 jury verdict which found that a mortgage lender violated, among other laws, the Equal Credit Opportunity Act (“ECOA”) by engaging in “reverse redlining” when it...more

California AB 3108 Creates Potential Mortgage Fraud Issue for Lenders on Owner-Occupied Mortgage Loans Made for a Business Purpose

California Assembly Bill 3108 became effective on January 1, 2025 and could conceivably make certain business purpose loans secured by owner-occupied property subject to mortgage fraud claims by the borrowers. The primary...more

CFPB Report Highlights Widespread Violations in Student Loan Sector

On December 16, the CFPB released a special edition of its Supervisory Highlights, which detailed findings from the Bureau’s recent examinations of student loan markets. The report identifies a range of violations related to...more

New CFPB Rule Applies Mortgage Standards to Residential PACE Financing

On December 17, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rule applying standard mortgage protections to Residential Property Assessed Clean Energy (PACE) loans. The rule amends Regulation Z to clarify...more

CFPB Bans Debt Collection Agency Over Student Loan Abuses

On December 9, the CFPB entered into a consent order with a debt collection agency for alleged unlawful student loan debt collection practices against defaulted borrowers. The debt collection agency’s allegedly improper...more

CFPB Study Finds Differential Treatment in the Small Business Lending Market

On November 13, the Consumer Financial Protection Bureau released a “pilot study” on the small business lending market revealing “significant disparities” in how lenders treat black and white small business owners. As part of...more

California Passes Law Extending new Protections to Mortgage Borrowers

On September 20, Governor Newsom signed AB 2424, which establishes a significant set of new foreclosure notification and sale requirements for mortgage lenders. The law is effective as of January 1, 2025....more

CFPB Settles Action Against Student Loan Servicer with Industry Ban

On September 12, 2024, the Consumer Financial Protection Bureau (CFPB) filed a proposed order which, if entered by the court, will ban a student loan servicer from servicing federal student loans and require it to pay $120...more

CFPB Penalizes VA Lender for Misrepresenting Cost of Cash-Out Refinance Loans

On August 29, the CFPB issued a consent order against a non-bank direct mortgage lender for misrepresenting the cost of its cash-out refinance loans, which are guaranteed under the VA home loan program, to active-duty...more

CFPB Cracks Down on Mortgage Servicers, Alleging Harmful Practices Against Older Homeowners

On June 18, the CFPB settled enforcement actions against two mortgage servicers who serviced reverse mortgages on behalf of HUD, for their systemic failure to respond to consumer requests for assistance, resulting in...more

CFPB Takes Action Against Owners of Small Dollar Lender for Hiding Money to Avoid Penalties

On June 17, the Consumer Financial Protection Bureau filed an order to resolve its 2023 lawsuit against the former CEO of a short-term small dollar lender and his spouse, in connection with a series of fraudulent transfers...more

CFPB Interpretive Rule Holds That BNPL Lenders Are Credit Card Providers

On May 22, the CFPB announced an interpretive rule confirming that Buy Now, Pay Later (BNPL) lenders qualify as credit card providers under the Truth in Lending Act, Regulation Z and are required to provide consumers legal...more

CFPB Sues Fintech for Deceptive Practices Surrounding Tipping Service

On May 17, the CFPB filed a lawsuit against a California-based fintech that operates a nationwide website and mobile-application based peer-to-peer lending platform through which consumers can obtain small-dollar, short-term...more

CFPB Settles Action Against Student Loan Servicer and Securitization Trusts

On May 6, 2024, the CFPB resolved an enforcement action against a group of Delaware student loan trusts and a loan servicer (found here and here) for their failures to adequately respond to borrowers’ requests for relief,...more

Ninth Circuit Holds Loan Modification Made By Unlicensed Lender Violates State Usury Law

In an April 16 unpublished opinion, the U.S. Ninth Circuit Court of Appeals affirmed the Bankruptcy Appellate Panel’s earlier decision finding that a mortgage lender not licensed in California violated the state’s usury law...more

Third Circuit Ruling Gives CFPB Green Light to Enforce Against Student Loan Trusts

In a significant ruling on March 19, the Third Circuit Court of Appeals held that the CFPB can proceed with its lawsuit against a group of Delaware student loan trusts rejecting their claims that they are just passive...more

CFPB Renews Push on “Junk Fees” with Closing Costs in its Sights

In its latest campaign against “junk fees,” the CFPB announced that it was requesting consumer feedback on fees incurred as part of the residential home loan closing process, such as title insurance, credit reporting, and...more

CFPB Issues Risk-Based Supervision Order Against Installment Lender

On February 23, the Consumer Financial Protection Bureau announced its first public decision designating a nonbank lender for supervision based on the institution’s potential risk to consumers....more

CFPB Files Action Against Fintech for Allegedly Violating Previous Order, Deceiving Customers, Withdrawing Funds Without Consent

On November 15, the CFPB issued an order requiring an Illinois-based fintech lender to pay $15 million in fines. The order additionally prohibits the company from operating in certain lines of business and requires revision...more

OCC Issues Bulletin on Risks Related to Venture Lending

On November 1, the OCC issued Bulletin 2023-34 addressing the topic of “venture lending,” referred to as “commercial loans to early-, expansion-, and late-stage companies.” According to the Bulletin, venture lending is often...more

California Court Denies DFPI’s Motion for Preliminary Injunction Against Fintech

On October 30, the Superior Court of California County of Los Angeles denied the DFPI’s motion for a preliminary injunction to force a Chicago-based fintech company to stop facilitating loans to California borrowers from its...more

CFPB 2022 Loan Data: Decrease in Originations; Increase Loan Payments, Fees

On September 27, the CFPB released its annual report on residential mortgage lending activity and trends for 2022. Under the Home Mortgage Disclosure Act (HMDA), the CFPB requires financial institutions to collect and provide...more

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