There is a tendency to think of consumer fraud and misrepresentation as intentional acts that deceive consumers into engaging in transactions that they would not otherwise engage in. A recent case demonstrates that the...more
On August 26, 2016, the Department of Defense (“DOD”) issued an interpretive rule (the “Interpretive Rule”) providing guidance on the DOD’s regulations implementing the Military Lending Act (“MLA”). That same day, we...more
9/16/2016
/ Credit Agreements ,
Credit Cards ,
Creditors ,
Department of Defense (DOD) ,
EFTs ,
Financial Institutions ,
Interpretive Rule ,
Loans ,
Military Annual Percentage Rates (MAPR) ,
Military Lending Act ,
Safe Harbors
As we previously reported in our June 3, 2016 client alert, the Consumer Financial Protection Bureau (“CFPB”) has issued a Notice of Proposed Rulemaking for short-term loans (“Proposed Rule”). In this follow-up alert, we take...more
7/21/2016
/ Ability-to-Repay ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Fair Lending ,
Lending ,
Loans ,
NCUA ,
NPRM ,
Payday Loans ,
Private Right of Action ,
Proposed Rules ,
Request For Information ,
Short-Term Loans ,
UDAAP
Recent initiatives by the Consumer Financial Protection Bureau (“CFPB” or Bureau) to dramatically expand its regulation of small business lending present a confluence of concerns to industry participants. These initiatives...more
On July 22, 2015, the Department of Defense (DOD) published sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more
8/3/2015
/ Active Duty ,
Amended Regulation ,
Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Credit Cards ,
Creditors ,
Department of Defense (DOD) ,
Disclosure Requirements ,
Finance Charges ,
Lenders ,
Loans ,
Military Lending Act ,
Payday Loans ,
Regulation Z