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Financing Consumer Financial Protection Bureau (CFPB)

McGlinchey Stafford

Credit, Tips, Obligation to Pay: CFPB Proposed Interpretive Rule Seeks to Clarify Earned Wage Access and Regulation Z

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On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued notice of a proposed interpretive rule (Rule) that walks back a prior 2020 Advisory Opinion on the manner in which Regulation Z defines “credit.” The...more

Cadwalader, Wickersham & Taft LLP

CFPB Issues Report on Concerns Regarding the Solar Financing Market

In this report on the solar financing marketplace, which is characterized as an “Issue Spotlight”, the CFPB identifies four areas that they view to present risks to consumers. In the press release accompanying the report,...more

Wiley Rein LLP

Wiley Consumer Protection Download (May 14, 2024)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Ballard Spahr LLP

Update on Petition to Review FTC’s CARS Rule

Ballard Spahr LLP on

Petitioners in the challenge to the Federal Trade Commission’s (“FTC”) Combating Auto Retail Scams Rule (“CARS Rule”) filed their Petitioners’ Brief on March 15, 2004 in support of their petition for review, and a who’s who...more

Morgan Lewis

FTC’s Final ‘Cars Rule’ on Dealer Sales Practices: Implications for Banks, Auto Finance, and ‘captives’

Morgan Lewis on

The Federal Trade Commission recently issued a final rule that is squarely aimed at changing the way dealers interact with customers in the financing process. The final rule takes effect on July 30, 2024....more

Husch Blackwell LLP

Medical Financing Disclosure Bill Introduced in Illinois

Husch Blackwell LLP on

On October 18, a bill was introduced in the Illinois legislature that, if enacted, would require medical providers to provide certain disclosures to patients when referring them to third-party medical financing plans. If...more

Cadwalader, Wickersham & Taft LLP

Multistate and CFPB Enforcement Actions Against Lease Finance Company Tempoe

The Consumer Financial Protection Bureau (“CFPB”) announced on Monday that it and 41 states and the District of Columbia had resolved a multistate investigation in the leasing activities engaged in by specialty consumer...more

Goodwin

Tougher Standards for Certain Home Improvement Loans

Goodwin on

On May 1, 2023, the Consumer Financial Protection Bureau (CFPB) issued a report and a proposed rule to clarify and strengthen its regulation of so-called Property Assessed Clean Energy (PACE) financing. PACE financing is...more

Troutman Pepper

Lots of Developments in Small Business Finance - The Consumer Finance Podcast

Troutman Pepper on

Please join Troutman Pepper Partner Chris Willis and his colleagues Caleb Rosenberg and Josh McBeain as they discuss a string of recent developments in small business financing at both the state and federal level, including...more

Shipkevich PLLC

California DFPI Proposes Regulation to Implement Registration Requirements for Entities Covered Under California Consumer...

Shipkevich PLLC on

The California Consumer Financial Protection Law (“CCFPL”), established in September of 2020 under Governor Newsom, augmented the Department of Financial Protection & Innovation’s (“DFPI”) authoritative ability by increasing...more

Jenner & Block

Consumer Financial Protection Bureau Proposes Rule to Create a Public Registry of Terms and Conditions in Consumer Contracts

Jenner & Block on

On January 11, 2023, the U.S. Consumer Financial Protection Bureau (the “CFPB”) proposed a new rule to create a public registry of terms and conditions in form contracts that waive or limit consumer rights. The registry would...more

Troutman Pepper

CFPB-New York AG Lawsuit Analyses Against Subprime Auto Financer - The Consumer Finance Podcast

Troutman Pepper on

Please join Troutman Pepper Partner Chris Willis for a solo episode as he shares his thoughts about the recent lawsuit between the CFPB and the New York State Office of the Attorney General against a subprime auto finance...more

Mayer Brown

CFPB Preliminarily Determines State Commercial Financing Disclosure Laws Not Preempted by Truth in Lending Act

Mayer Brown on

Small business lenders hoping for federal intervention will be disappointed to learn that the Consumer Financial Protection Bureau (CFPB) has reached a preliminary determination that New York’s new commercial financing...more

McGlinchey Stafford

Extensions on extensions: Financing despite low inventory

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Dealers continue to struggle with inventory shortages that frustrate sales staff and potential customers. In many cases, potential customers are ready, willing and able to finance a specific vehicle or type of vehicle if it...more

McGlinchey Stafford

CFPB eyes unfair, deceptive acts: Technology and repossessions

McGlinchey Stafford on

The Consumer Financial Protection Bureau (CFPB) recently issued two bulletins highlighting its concerns with business practices in the auto finance and servicing industries as a result of inflation and the potential for...more

McGlinchey Stafford

CFPB Eyes Unfair, Deceptive Acts: Here Are Some Tips To Avoid Scrutiny

McGlinchey Stafford on

With a new administration comes new priorities for federal agencies, and the Consumer Financial Protection Bureau (CFPB) is no different. During the Trump administration, the Bureau focused on “educating” consumers. Under...more

Manatt, Phelps & Phillips, LLP

Student Lending: CFPB Investigates Point-of-Sale Financing

A leading online payments system platform that offers point-of-sale (POS) financing reports it received a Civil Investigative Demand (CID) from the Consumer Financial Protection Bureau (CFPB) for allowing educational...more

Goodwin

SEC Issues No-Action Relief On Registered Funds’ Custody Of Loan Interests

Goodwin on

In this Issue. The U.S. Securities and Exchange Commission (SEC) was very active this week, having (i) issued no-action relief allowing registered funds to engage in self-custody of interests in loans that are originated,...more

Morrison & Foerster LLP

CFPB Seeks Input On Improving Access To Credit

On August 3, 2020, the Consumer Financial Protection Bureau (CFPB) published a Request for Information (RFI) that seeks comment on ways to clarify the Equal Credit Opportunity Act’s (ECOA) implementing regulation, Regulation...more

Ballard Spahr LLP

Industry Trade Groups Respond to FHFA Request for Input on PACE Transactions

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In January 2020 the Federal Housing Finance Agency (FHFA) published a request for input on Property Assessed Clean Energy (PACE) transactions involving residential property. ...more

Ballard Spahr LLP

Department of Defense Reverts to Prior Position on MLA Interpretive Rule Q&A #2 Regarding Motor Vehicle and Personal Property...

Ballard Spahr LLP on

In a new interpretive rule published on February 28, 2020, the Department of Defense (DoD) has announced that it is withdrawing guidance previously issued in its December 14, 2017 Interpretive Rule, Q&A #2, governing motor...more

White and Williams LLP

PACE Loan Considerations for Commercial Real Estate Lenders

Property Assessed Clean Energy (PACE) loans provide property owners with financing for “green” improvements designed to increase energy efficiency, water conservation, disaster resiliency and renewable energy solutions. PACE...more

Ballard Spahr LLP

GAO to opine on whether CFPB indirect auto finance guidance is a rule subject to disapproval under the Congressional Review Act

Ballard Spahr LLP on

American Banker has reported that the Government Accountability Office has accepted a request from Senator Pat Toomey on whether the CFPB’s indirect auto finance guidance issued in March 2013 is a “rule” under the...more

Ballard Spahr LLP

CFPB conducts small business field hearing and issues related white paper and request for information

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Yesterday, I attended the CFPB’s field hearing in Los Angeles on small business lending. In connection with the hearing, the CFPB issued a white paper entitled “Key dimensions of the small business lending landscape,”...more

Ballard Spahr LLP

FTC sends 2016 ECOA report to CFPB

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The FTC has sent its annual letter to the CFPB reporting on the FTC’s activities related to compliance with the Equal Credit Opportunity Act and Regulation B. The FTC has authority to enforce the ECOA and Reg B as to...more

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