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Consumer Financial Products Regulatory Requirements

Mayer Brown

Missouri Regulates Providers and Brokers Under New Commercial Financing Law

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Missouri has enacted the nation’s ninth state commercial finance disclosure law, regulating the providers and brokers of certain commercial financing transactions. Signed by Governor Mike Parson on July 11, 2024, Missouri...more

Skadden, Arps, Slate, Meagher & Flom LLP

How and When SEC Recordkeeping Rules May Apply to AI-Generated Content

AI has revolutionized the way many businesses operate. Firms in the financial sector are eager to take advantage of rapidly developing technologies but do not want to risk running afoul of relevant Securities and Exchange...more

GeoDataVision

Is Fair Lending Enforcement Fair Today? Part II

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Previously, I have written about regulatory enforcement of anti-redlining regulations. I pointed out the problems and potentially misleading statistical conclusions caused by the application of what is called a “REMA” or...more

Troutman Pepper

Highlights from the CFPB’s Spring 2024 Semi-Annual Regulatory Agenda

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The Consumer Financial Protection Bureau (CFPB or Bureau) recently released its semi-annual regulatory agenda, outlining its planned rulemaking initiatives. The CFPB releases regulatory agendas twice a year in voluntary...more

Ballard Spahr LLP

CFPB Releases Mortgage Servicing Report on Borrower Experiences During the COVID-19 Pandemic

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The complexity of loss mitigation programs designed to assist distressed mortgage borrowers during the COVID-19 pandemic may have been too daunting for many borrowers to seek help, the CFPB said, in a report released last...more

Ballard Spahr LLP

CFPB Issues Proposed Rule Amending Mortgage Servicing Rules

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The CFPB recently issued its long-awaited proposed rule amending the mortgage servicing rules under Regulation X, with a focus on streamlining and expanding the loss mitigation procedures and foreclosure protections. The...more

Hinshaw & Culbertson - Consumer Crossroads

What Does the CFPB’s New Public Registry to Detect Repeat Offenders Mean for Your Business?

On June 3, 2024, the Consumer Financial Protection Bureau (CFPB) issued the Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders Final Rule (“the Final Rule”)....more

Skadden, Arps, Slate, Meagher & Flom LLP

Colorado’s Landmark AI Act: What Companies Need To Know

Colorado has become the first state to enact a comprehensive law relating to the development and deployment of certain artificial intelligence (AI) systems. The Colorado Artificial Intelligence Act (CAIA), which will go into...more

Ballard Spahr LLP

Connecticut Department of Banking issues guidance on consumer-like disclosures in sales-based financing offers

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On June 10, 2024, the Connecticut Department of Banking (“Department”) issued guidance (the “Guidance”) to give direction on required consumer-like disclosures in certain commercial financing offers....more

Ballard Spahr LLP

CFPB issues report on negative equity in auto financing

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A new CFPB report, “Negative Equity in Auto Lending,” contains an analysis of data relating to the financing of negative equity in vehicle trade-ins. The report uses data collected by the CFPB in response to nine market...more

Shipkevich PLLC

CFPB to Begin Tracking Offenders through National Registry

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The CFPB has issued a final rule to provide transparency and track certain covered nonbank offenders. On June 3, 2024, the CFPB introduced a significant regulatory measure known as the Registry of Nonbank Covered Persons...more

Ballard Spahr LLP

Minnesota federal court dismisses lawsuit against FDIC over NSF fee guidance

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On April 8, 2024, a Minnesota federal district court dismissed without prejudice the complaint filed by the Minnesota Bankers Association and Lake Central Bank (Plaintiffs) against the Federal Deposit Insurance Corporation...more

GeoDataVision

Will the Regulators Implement a Key CRA Rule Component by Stealth?

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Now that a Texas court has issued a temporary injunction delaying the April 1, 2024, scheduled implementation of the new CRA Rule should bankers relax and assume that the new rule’s effective date has been delayed for at...more

Ballard Spahr LLP

FDIC final Signage and False Advertising Rule will be effective April 1, 2024, with an extended full compliance date of January 1,...

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The final rule issued in December 2023 by the Federal Deposit Insurance Corporation (FDIC) amending its regulations at 12 CFR Part 328 (“Final Rule“), which address use of the official FDIC sign and banks’ advertising...more

GeoDataVision

Postponement of April 1, 2024 “Applicable” Date May Cause More Confusion

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The March 21, 2024, announcement that the prudential bank regulators have decided to postpone the scheduled April 1, “applicable” date for the Facility-based assessment areas, the new Public File section and the Public Notice...more

GeoDataVision

The Answers to the CRA Questions Everyone is asking: What must we do on April 1?

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With April 1, 2024, the effective date for the new CRA rule fast approaching, every bank is asking what must we do on April 1? Here are the answers....more

Troutman Pepper

Proposed Legislation in Louisiana Aims to Regulate Commercial Financing Transactions

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On March 1, Senate Bill (SB) 335 was introduced, which, if passed, would impose certain requirements on “commercial financing transactions.” Recently, multiple states have enacted disclosure regulations for commercial...more

Mayer Brown

FHA Branch Offices Could Become a Thing of the Past: HUD Finalizes Rule Eliminating Mandatory Branch Office Registration

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Federal Housing Administration (“FHA”) approved lenders and mortgagees will no longer be required to register their branch offices. The US Department of Housing and Urban Development (“HUD”) published a final rule (the “Final...more

Ballard Spahr LLP

CFPB seeks approval for new auto finance data collection

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The CFPB recently published a notice in the Federal Register indicating that it is seeking approval from the Office of Management and Budget (OMB) for the collection of additional auto finance data pursuant to its authority...more

GeoDataVision

The New CRA Rule: Another Surprise – for Banks and maybe for the Regulators too (part of a series taking a critical look at the...

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The new CRA Rule has a number of surprises for banks and maybe a surprise or two for the regulators themselves. One of those surprises involves the transition rules in §__.51 as they pertain to the April 1, 2024, the...more

Payactiv

Consumer Protection Priorities in Earned Wage Access Legislation

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In recent years, earned wage access (EWA) – an innovative technology that enables workers to access their own, already earned wages without having to wait for payday – has rapidly become a table stakes employee benefit. By...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - November 2023 # 2

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Carlton Fields

Expect Focus - Volume III, September 2023

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Regulators Hit Jackpot: Off-Channel Communications - Several years before announcing the first “off-channel” communications enforcement action, the SEC and FINRA cautioned broker-dealers and investment advisers about...more

Jones Day

France Tightens Registration Conditions for Digital Assets Service Providers

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In Short - The Situation: France has had a registration and licensing process for digital assets service providers for over three years. The recent crisis with Terra Luna and FTX trading platform has made it clear to...more

Akerman LLP

Explainer Things: Episode 9

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Fall is finally in the air as temperatures drop (in some parts of the country, at least) and football season is in full swing. We’ve previously avoided writing about football because our Explainer Things cast can’t agree on...more

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