This week, the Office of the Comptroller of the Currency (OCC) issued guidance to banks on managing the risks associated with “buy now, pay later” (BNPL) lending. Specifically, the bulletin addresses BNPL loans that are...more
On December 1, Freddie Mac issued Bulletin 2021-36 to update lenders on changes in loan eligibility requirements. While it is not unusual for Freddie Mac to issue such bulletins, this bulletin contained changes pertaining to...more
Illinois Governor J.B. Pritzker signed the Illinois Predatory Loan Prevention Act (Act) into immediate effect on March 23. The Act imposes sweeping changes and contains broad language, leaving the state’s lenders and...more
On April 23, the Small Business Administration (SBA) informed borrowers, via Question #31 in the Paycheck Protection Program (PPP) Frequently Asked Questions (FAQ), that “all borrowers must assess their economic need for a...more