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CFPB Departs From Precedent and Reverses Itself by Proposing Novel Interpretive Rule That Applies TILA and Regulation Z to...

On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule (Proposed Rule) applying the Truth in Lending Act (TILA) and Regulation Z (collectively referred to hereafter as Regulation Z) to...more

CFPB Deems Merchant Cash Advances to Be “Credit” Under ECOA

The Consumer Financial Protection Bureau’s adopting release for its small business data collection and reporting rule goes beyond that rule by including a discussion deeming merchant cash advances to be “credit” more...more

Treasury Department’s FSOC Acknowledges Climate Change as Threat to Financial Stability

In This Issue. The Treasury Department’s Financial Stability Oversight Council (FSOC) issued a report acknowledging climate change as threat to financial stability; Federal Reserve Governor Michelle Bowman advocates for...more

OCC Grants National Trust Bank Charter to Third Cryptocurrency Firm

In This Issue. The Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval to a third cryptocurrency firm chartering a national trust bank; the Consumer Financial Protection Bureau (CFPB)...more

SBA and Treasury Department Issue New Guidance on PPP

In this Issue. The Office of the Comptroller of the Currency (OCC) issued guidance on its authority to charter limited purpose trust companies, raising the possibility that a limited purpose national bank could be organized...more

CFPB Affirms Regulation Z Does Not Apply To Non-Recourse Earned Wage Access

Recently, the Consumer Financial Protection Bureau (CFPB) issued an order accepting into the CFPB’s compliance assistance sandbox an earned wage access (EWA) program where participating employees are not obligated to repay...more

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