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New California Law Impedes Creditors' Ability to Offer Voluntary Protection Products to Military Servicemembers

California recently enacted Senate Bill 1311, the Military and Veteran Consumer Protection Act of 2022, with the stated intent of strengthening the state's military consumer protection laws by enhancing protections for...more

Thinking of Accepting Payments from Customers via Discretionary Military Allotments? Think Again.

Accepting payments via discretionary military allotments has long been suspect in the eyes of the Consumer Financial Protection Bureau. Military allotments are automatic deductions from military pay. Allotments can be...more

Stuck in a Time Loop: The Compliance Clock Is Still Ticking for Small-Dollar Lenders in 2021

During the past year, small-dollar lenders learned the fate of the Consumer Financial Protection Bureau’s (“CFPB”) final rulemaking addressing payday, vehicle title, and certain high-cost installment loans. In addition, the...more

Equality in Credit Decisions – “Sex” DOES include Sexual Orientation and Gender Identity

In 2020, the Supreme Court held in Bostock v. Clayton County, Georgia that an employer who fires an employee for being gay or transgender violates the Civil Rights Act of 1964 (“Title VII”). Though the list of protected...more

Tik Tok: The Compliance Clock Is Ticking for Small-Dollar Lenders in 2020

[co-author: Hurshell K. Brown - Beyond Finance, LLC] INTRODUCTION - Small-dollar lenders waited through most of 2020 for the Consumer Financial Protection Bureau’s (“CFPB’s”) final rulemaking addressing payday, vehicle...more

New Policy on Prohibition of Abusive Acts or Practices - What do you need to know?

In 2010, the Dodd-Frank Act for the first time made it unlawful for persons to engage in an “abusive act or practice.” The “abusive” standard was added to the existing “UDAP” standard—unfair, deceptive acts and practices,...more

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