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Disclosure Requirements Consumer Lenders

Hudson Cook, LLP

[Webinar] Preparing for the New CFPB Enforcement Order Registry - June 27th, 2:00 pm ET

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Nonbank financial services companies with prior enforcement orders are preparing for the Consumer Financial Protection Bureau’s (CFPB) new Registry, which takes effect September 16. Nonbank consumer lenders, loan servicers,...more

Alston & Bird

Consumer Finance ABstract 2023 Year-End Reprise

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As we reflect on the previous year and look toward the new year, we thought you’d appreciate our top 20 most-read Consumer Finance ABstract posts from 2023...more

Barnea Jaffa Lande & Co.

Price Display in Credit Transactions: What are the Obligations?

The Haifa District Court recently handed down a ruling in a motion to certify a class action filed against Ofir Tours Ltd. by its customer. The plaintiff bought an Eilat hotel vacation through Ofir Tours, paying in credit...more

Latham & Watkins LLP

HM Treasury Publishes Draft Legislation to Regulate BNPL Lending

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A consultation that will remain open until 11 April 2023 offers further clarity on the proposals to regulate buy-now-pay-later products. On 14 February 2023, HM Treasury published its consultation and accompanying draft...more

Hudson Cook, LLP

What You Say May Undo What You Do

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The retail installment sales contracts used by auto dealerships include disclosures related to GAP insurance and other debt cancellation products that are required under the federal Truth in Lending Act in order for the...more

Mayer Brown

Legal Update: NY Enacts TILA-Like Disclosure Law for Business Loans and Purchases of Receivables (Factors, MCA Providers,...

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In late December 2020, New York Governor Andrew Cuomo signed S.B. 5470 into law, which will impose a range of Truth in Lending Act-like disclosure requirements on providers of commercial financing in amounts of $500,000 or...more

Ballard Spahr LLP

CFPB Publishes TRID FAQ’s on Treatment of Lender Credits

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The CFPB recently published ten new TRID FAQs related to lender credits. Previously the CFPB staff provided informal verbal guidance regarding lender credits, and the 2017 amendments to the TRID rule, often referred to as...more

Ballard Spahr LLP

Georgia and Colorado Address MLO Temporary Authority to Operate

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Following receipt and consideration of three written comments on proposed rules distributed on November 18, 2019, the Georgia Department of Banking and Finance adopted final rules on December 20, 2019, that establish...more

Ballard Spahr LLP

CA on the verge of requiring commercial finance disclosures

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It appears likely that California Governor Jerry Brown will sign a bill passed on August 31 by the state’s Senate, Senate Bill 1235, which would create consumer-style disclosure requirements for certain commercial loans and...more

Robins Kaplan LLP

Your Daily Dose Of Financial News

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Last Friday, the White House asked the SEC to “consider eliminating requirements that publicly traded companies post quarterly earnings reports.” Such disclosures, however, are required by federal securities law, so they’re...more

Ballard Spahr LLP

CFPB enters into consent order with small-dollar lender to settle alleged TILA and UDAAP violations arising from finance charge...

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The CFPB announced last week that it has entered into a consent order with Triton Management Group, Inc., a small-dollar lender, to settle the CFPB’s allegations that Triton had violated the Truth in Lending Act and the...more

Ballard Spahr LLP

NYDFS calls for application of NY usury limits to all online lending and more regulation in online lending report

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The New York Department of Financial Services (NYDFS) has issued an Online Lending Report that calls for the application of New York usury limits to all online lending and increased regulation of online lenders making loans...more

Ballard Spahr LLP

New York City adopts new requirements for used car dealers

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The New York City Department of Consumer Affairs (DCA) has adopted new rules for used car dealers, requiring all licensed dealers to make additional disclosures to consumers and creating a new consumer bill of rights for the...more

Ballard Spahr LLP

CFPB Finalizes Black Hole Fix under TRID Rule

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The CFPB, which is now referring to itself as the “Bureau of Consumer Financial Protection,” published the long-awaited final rule to address the so-called “black hole” issue under the TILA/RESPA Integrated Disclosure (TRID)...more

Ballard Spahr LLP

CFPB Finalizes Black Hole Fix under TRID Rule

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The Consumer Financial Protection Bureau (CFPB) published the long-awaited final rule to address the so-called "black hole" issue under the TILA/RESPA Integrated Disclosure (TRID) rule. ...more

Mintz - Real Estate, Construction &...

California Usury Law: A Search for Clarity around Compound Interest

California usury law is addressed in multiple places: the California Constitution, statutes, case law, and initiative measures. Due to the patchwork nature of this body of law, differing interpretations and ambiguity are...more

Smith Debnam Narron Drake Saintsing & Myers,...

District Court Holds that the Verbiage, “Settlement Offers May Have Tax Consequences”, in a Debt Collector’s Form Collection...

The Western District Court in New York has held that a debt collector did not violate § 1692e(10) of the FDCPA. The Court held that a form collection letter with offers of settlement did not “use… false representation or...more

Ballard Spahr LLP

Education Dept. says state student loan servicing laws are preempted

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In response to the wave of new state student loan servicing laws and enforcement activity, the U.S. Department of Education has published an interpretation emphasizing that the Higher Education Act (HEA) preempts state...more

Ballard Spahr LLP

New York City proposes new disclosure requirements for used car dealers

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The New York City Department of Consumer Affairs (DCA) has proposed new rules for used car dealers that would require dealers to provide the following disclosures to buyers...more

Jones Day

The European Securitisation Regulation: The Countdown has Begun....

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Draft Technical Standards Published for Consultation by the European Supervisory Authorities—An Update and Overview - Regulation (EU) 2017/2402, which is known as the "Securitisation Regulation" and lays down a general...more

Ballard Spahr LLP

CFPB releases report on college credit card agreements

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The CFPB released its sixth annual report to Congress on college credit card agreements.  The annual report is mandated by the CARD Act. ...more

Ballard Spahr LLP

CFPB updates TRID Rule small entity compliance guide

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The CFPB recently released a revised version of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide. The revised version incorporates the recent amendments to the rule that became effective on October...more

Ballard Spahr LLP

House Financial Services Committee schedules Oct. 11 mark-up of “Madden fix” bill

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Among the more than 20 bills that the House Financial Services Committee is scheduled to mark-up this Wednesday, October 11, is a bill to provide a “Madden fix” as well as several others relevant to consumer financial...more

Ballard Spahr LLP

CFPB releases summary of TRID Rule amendments

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In July, the CFPB finalized amendments to the TILA/RESPA Integrated Disclosure (TRID) rule.   Published in the Federal Register earlier this month, the amendments will become effective on October 10, 2017, with a mandatory...more

Ballard Spahr LLP

Guidance from the OCC to banks regarding higher loan-to-value loan programs

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On August 21, 2017, the Office of the Comptroller of the Currency (OCC) published Bulletin 2017-28 regarding higher-loan-to-value (LTV) lending programs (the “Bulletin”). Recognizing the need for further revitalization...more

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