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Ability-to-Repay UDAAP

Ballard Spahr LLP

CFPB Moves To Dismiss Lawsuit Challenging Its Rescission Of Mandatory Underwriting Provisions Of 2017 Payday/Auto Title/High-Rate...

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The CFPB has filed a motion to dismiss the federal district court lawsuit brought by the National Association for Latino Community Asset Builders (NALCAB). That lawsuit seeks to overturn the CFPB’s July 2020 final rule (2020...more

Ballard Spahr LLP

Director Kraninger testifies at House and Senate hearings

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CFPB Director Kraninger was the sole witness at a House Financial Services Committee hearing thsi week on the Bureau’s Spring 2019 semi-annual report and at a Senate Banking Committee hearing yesterday on the report. ...more

Ballard Spahr LLP

Ballard Spahr critiques CFPB payday loan rule’s payment provisions

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Last month, Ballard Spahr submitted two letters to the CFPB, critiquing the payment provisions of the CFPB’s final payday/auto title/high-rate installment loan rule (the “Payment Provisions”). ...more

Ballard Spahr LLP

State AGs threaten action against CFPB for delaying compliance date for payday loan rule

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A group of 24 Democratic state attorneys general and the D.C. attorney general have submitted a comment letter to the CFPB setting forth their opposition to the CFPB’s proposal to delay the compliance date for the...more

Bradley Arant Boult Cummings LLP

A Deeper Dive: The CFPB Short-Term Small- Dollar Lending Rule

Introduction - By now you’ve likely heard that the Consumer Financial Protection Bureau (CFPB) has released a final small-dollar lending rule. The hallmark of the rule is the requirement That lenders make a reasonable...more

Ballard Spahr LLP

CFPB issues Fall 2016 Supervisory Highlights

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In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more

Morrison & Foerster LLP

A Closer Look at the CFPB’s Proposed Short-Term Lending Rule

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

Morrison & Foerster LLP

Short-Term Lenders Face Costly Path To Compliance

On June 2, 2016, the Consumer Financial Protection Bureau released its long-anticipated notice of proposed rulemaking on short-term consumer lending. The proposed rule follows the CFPB’s March 2015 release of an outline of...more

BCLP

The CFPB Proposes Ambitious Payday Lending Regulations

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On June 2, 2016, the CFPB released its long-awaited proposed regulations for payday loans, vehicle title and certain high-cost installment loans. Comments on the proposed rules must be received on or before September 14,...more

Dorsey & Whitney LLP

The Moronta Decision in Massachusetts – Determining A Borrower’s Ability To Repay

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A recent decision by the Massachusetts Court of Appeals highlights some of the challenges lenders may face when seeking the dismissal of allegations of unfair and deceptive lending practices in connection with a loan that...more

MoFo Reenforcement

CFPB Seeks Comments on Consumer Credit Card Market

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On Tuesday, March 17, the Consumer Financial Protection Bureau (CFPB) announced a “Request for Information Regarding Credit Card Market.” It follows the 2009 CARD Act’s requirement that the CFPB conduct a review of the...more

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