On September 18, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a set of frequently asked questions (FAQs) providing guidance on applying Regulation Z requirements to Pay-in-Four Buy Now, Pay Later (BNPL)...more
Since 2022, the Consumer Financial Protection Bureau (CFPB) has a stated priority of “protecting employees and their rights through conducting reports, inquiries, and issuing requirements for employers.” In July 2024, the...more
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed interpretive rule on earned wage access (EWA) products (“Proposed Interpretive Rule”) that, if finalized, would clarify that EWA products are...more
On July 18, 2024, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) proposed an interpretive rule that states (1) EWA products fall under the definition of “credit” under the Truth in Lending Act (“TILA”) and...more
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule (Proposed Rule) applying the Truth in Lending Act (TILA) and Regulation Z (collectively referred to hereafter as Regulation Z) to...more
Following its recent win before the Supreme Court, the Consumer Financial Protection Bureau (CFPB or Bureau) on May 22, 2024, issued an interpretive rule concluding that “Buy Now, Pay Later” (BNPL) loans accessed through a...more
The Consumer Financial Protection Bureau (CFPB ) has issued an interpretive rule stating that Buy Now, Pay Later (BNPL) loan providers are "card issuers" under Subpart B of Regulation Z and are thus subject to certain...more
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule indicating that certain Buy Now, Pay Later (BNPL) products are subject to certain provisions of Regulation Z that apply to credit...more
The result of the CFPB’s multi-year study of the BNPL industry is what the CFPB calls an interpretive rule in which it finds that: (1) “digital user accounts” (each a “DUA”) that may be used to access credit are “credit...more
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an “interpretive rule,” subjecting “Buy Now, Pay Later” (BNPL) transactions to provisions of Regulation Z applicable to “credit cards.” Among other...more
On August 10, the CFPB issued an interpretive rule stating that digital marketing providers that are involved in the identification or selection of prospective customers or the selection or placement of content to affect...more
In the heat of summer, the nation’s top consumer protection agencies have issued startling and transformative statements and rules regarding data practice. First up, the Consumer Financial Protection Bureau issued a...more
The CFPB is the primary regulator of consumer financial products and services in the US, but other state and federal regulators also have authority to enforce some federal consumer financial protection laws. The CFPB is now...more
Regulatory Announcements- CFPB Issues Advisory Opinion on FCRA Permissible Purposes for Providing Consumer Reports. On July 7, the CFPB issued an Advisory Opinion on the Fair Credit Reporting Act (FCRA) that outlines...more
The Consumer Financial Protection Bureau ("the Bureau" or CFPB) released an Interpretive Rule - which is exempt from notice-and-comment requirements of the Administrative Procedure Act - that sets out its view on the power of...more
The Consumer Financial Protection Bureau ("CFPB") issued an interpretive rule on May 19, reiterating the authority that states have to pursue companies and individuals that violate federal consumer financial protection laws,...more
The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion on May 9, confirming that for purposes of the Equal Credit Opportunity Act (“ECOA”) and its implementing regulation, Regulation B, the intended...more
The year 2020 marked the five-year anniversary of the TILA-RESPA Integrated Disclosure rule (TRID Rule). While the year passed without any additional formal rulemaking from the Consumer Financial Protection Bureau (Bureau or...more
In This Issue. The Consumer Financial Protection Bureau (CFPB) issued an interpretive rule on Fair Credit Report Act consumer information matching requirements; the Securities and Exchange Commission (SEC) approved the Public...more
Late last week, the Consumer Financial Protection Bureau (CFPB) released an interpretive rule that provided much-welcome guidance related to the effect of the new Juneteenth National Independence Day on disclosure waiting...more
Anti-discrimination efforts are front and center for the Consumer Financial Protection Bureau. This is evident by the interpretive rule it recently issued relating to the Equal Credit Opportunity Act (ECOA) and Regulation B....more
On March 9, 2021, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an Interpretive Rule that the prohibitions against sex discrimination in the Equal Credit Opportunity Act (ECOA) and Regulation B encompass...more
In This Issue. The Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) issued a Risk Alert about the scope and content of examinations OCIE plans to conduct of various...more
On June 23, 2020, the CFPB published a new interpretive rule (the “Interpretive Rule”) to update the Home Mortgage Disclosure Act (HMDA) data fields that are used to identify “underserved” areas. ...more
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