On February 26, 2021, Georgia introduced HB 674, which would authorize earned wage access (EWA) providers to operate in the state and avoid loan characterization by meeting certain requirements, including registration....more
On October 7, 2020, the CFPB announced that it was "provid[ing] clearer rules of the road for RESPA marketing service agreements" in the mortgage industry by rescinding its 2015 guidance regarding marketing services...more
Lightning never strikes twice, as the saying goes. But as many merchants are finding out these days, misfortune, in fact, strikes in threes. Not only has COVID-19 caused a substantial slowdown in the U.S. economy and...more
On October 21, 2019, the District Court for the Southern District of New York entered a final judgment in favor of the New York State Department of Financial Services (NYDFS), blocking the Office of the Comptroller of the...more
On November 15, 2018, the Board of Governors of the Federal Reserve System (Board) published in the Federal Register its request for public comment on potential actions the Federal Reserve could take to “promote ubiquitous,...more
Federal and state fair lending regulators are charting different courses for the future of “disparate impact” liability under the Equal Credit Opportunity Act and analogous state law....more
For many months, the Consumer Financial Protection Bureau (Bureau) has hinted it would focus its enforcement efforts on debt collection conduct. The Bureau’s settlement earlier this month with Security Group Inc., Security...more
In an en banc decision issued last Tuesday, the Third Circuit held that civil actions alleging violations of the Fair Debt Collection Practices Act (FDCPA) must be filed within one year from the date of the violation’s...more