On December 13, 2018, the CFPB published a proposed rule, seeking public comment regarding a change to its policy on No-Action Letters, as well as a new feature called the “Product Sandbox,” a rule change that was initially...more
On September 14, 2018, the Community Financial Services Association of America, Ltd. and the Consumer Service Alliance of Texas (Industry Groups) moved for a preliminary injunction to prevent many of the provisions of the...more
On August 13, 2018, the California Supreme Court answered a question certified to it by the Ninth Circuit, holding that a loan with a high interest rate can be unconscionable, even if the legislature specifically declined to...more
8/28/2018
/ Ability-to-Repay ,
Appeals ,
CA Supreme Court ,
CashCall ,
Consumer Financial Products ,
Consumer Lenders ,
Finance Lenders Law ,
Financial Services Industry ,
High-Interest Loans ,
Interest Rates ,
Unconscionable Contracts ,
Unfair Competition Law (UCL) ,
Usury
On June 21, 2018, a judge in the Southern District of New York ruled that the Consumer Financial Protection Bureau’s (CFPB’s) single director structure is unconstitutional. See CFPB v. RD Legal Funding LLC (2018 WL 3094916...more
On July 20, 2017, the CFPB announced that updates to its Spring 2017 rulemaking agenda have been posted online on the Office of Management and Budget’s webpage. The amended agenda highlights both areas of anticipated...more
In August, the CFPB issued a compliance bulletin to clarify lenders’ obligations to terminate Private Mortgage Insurance (PMI) charges under 12 U.S.C. § 4902. One subject that the bulletin did not address—but which is...more