News & Analysis as of

Military Lending Act

Hudson Cook, LLP

Federal Agencies Take Another Shot at GAP Coverage for Buyers Covered by the Military Lending Act

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I have always been a fan of suspenseful entertainment. I really like television shows where it looks like the protagonist is doomed, but then escapes, lands back in trouble, and gets out ... again! So fun. Originally...more

Venable LLP

Buy-Now-Pay-Later: A 360 Degree Overview

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Buy-Now-Pay-Later (BNPL) products are taking center stage as a popular way for consumers to purchase goods or services now and pay for them over time through a short series of installments, often interest-free. Industry...more

Hudson Cook, LLP

CFPB Bites of the Month - January Top 10

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Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month's article, we...more

Wiley Rein LLP

Wiley Consumer Protection Download (November 29, 2021)

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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

Bill reintroduced in House to impose 36% “all-in” rate cap

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A group of Democratic House members, joined by a Republican House member, has reintroduced a bill  (H.R. 5974) that would make consumer credit extended to any consumer subject to the Military Lending Act’s “all-in” 36% rate...more

Hudson Cook, LLP

CFPB Bites of the Month - November Top 10

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Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month's article, we...more

Goodwin

CFPB Files Complaint Against Pawnshop Lenders for Alleged Military Lending Act Violations

Goodwin on

On November 12, 2021, the Consumer Financial Protection Bureau (CFPB) announced that it filed a complaint in the United States District Court for the Northern District of Texas against two pawnshop lenders, alleging...more

Troutman Pepper

Department of Justice Enters Into Consent Orders for Violations of the Servicemembers Civil Relief Act

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In late September, the Department of Justice (DOJ) entered into two consent orders to resolve allegations related to violations of the Servicemembers Civil Relief Act (SCRA). The past year has seen an uptick in regulatory...more

Ballard Spahr LLP

National Defense Authorization Act amends SCRA to restrict use of arbitration agreements and waivers of SCRA protections

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In addition to amendments to the Fair Credit Reporting Act dealing with the reporting of adverse information on servicemembers by consumer reporting agencies, the National Defense Authorization Act (NDAA) as passed by the...more

Morrison & Foerster LLP

Financial Services Report - Fall 2021

We start this issue with a big, virtual welcome to our new colleague Maria Earley. Maria joined us last month as a partner in our Financial Services and Fintech Groups. She represents financial services and fintech companies...more

Spilman Thomas & Battle, PLLC

All Consuming - Financial Litigation Insights, Volume 2, Issue 16

President Biden Extends Pause on Student Loan Payments to 2022 - "Student loan payments have been paused since Congress passed the CARES Act in March of last year but were due to resume in September." Why this is...more

Hudson Cook, LLP

CFPB Bites of the Month - July Top 10

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So what happened at the CFPB in the past month? Bite #10 - The CFPB released its Spring 2021 rulemaking Agenda. The CFPB published its Spring 2021 rulemaking Agenda, which outlines the current plans for the CFPB...more

Goodwin

SEC Announces Annual Regulatory Agenda

Goodwin on

In This Issue. Several federal financial regulatory agencies updated their Spring 2021 regulatory agendas; the Consumer Financial Protection Bureau (CFPB) announced its intention to restart Military Lending Act examinations;...more

Ballard Spahr LLP

Dept. of Defense issues report to Congress on Military Lending Act rate cap

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The Department of Defense (DoD) has issued a report to the House Committee on Armed Services regarding the impact of a Military Annual Percentage Rate (MAPR) cap lower than 30% on military readiness and servicemember...more

Troutman Pepper

CFPB Issues Interpretive Rule Outlining Authority to Conduct MLA Examinations

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On June 16, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule to explain the basis for its position that the CFPB possesses the authority to “examine supervised financial institutions for risks to...more

Weiner Brodsky Kider PC

CFPB Issues Interpretive Rule on MLA-Related Examination Authority

The CFPB recently published an interpretive rule reasserting its authority to examine supervised financial institutions for Military Lending Act (MLA) violations and explaining the legal basis for such authority.  The new...more

Sheppard Mullin Richter & Hampton LLP

CFPB to Resume Examinations Under the Military Lending Act

On June 16, the CFPB issued an interpretive rule reversing its prior determination that it lacked authority to examine institutions for compliance with the Military Lending Act (MLA). In 2018, the CFPB discontinued checking...more

Kaufman & Canoles

Consumer Finance Client Alert – June 2021

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CFPB Reasserts Its Authority To Oversee/Supervise Lending to Military Personnel - The Consumer Financial Protection Bureau (CFPB) issued an interpretive rule on June 16, 2021 supporting its determination that it has the...more

Ballard Spahr LLP

CFPB to resume examinations for Military Lending Act compliance

Ballard Spahr LLP on

In another action demonstrating that a “new CFPB” is in place under the Biden Administration, the CFPB has issued an interpretive rule setting forth the basis for its determination that it has authority to examine...more

Troutman Pepper

New Illinois Predatory Loan Prevention Act Leaves Lenders and Borrowers with Uncertain Future

Troutman Pepper on

Illinois Governor J.B. Pritzker signed the Illinois Predatory Loan Prevention Act (Act) into immediate effect on March 23. The Act imposes sweeping changes and contains broad language, leaving the state’s lenders and...more

Bradley Arant Boult Cummings LLP

Illinois Caps Consumer Loans at 36% Rate, Limiting Consumers’ Access to Credit

Last week, Illinois enacted the “Predatory Loan Prevention Act” (SB 1792), which would place a 36% rate cap on nearly all non-bank consumer loans. This act will essentially outlaw small-dollar loans in Illinois and may make...more

Ballard Spahr LLP

Illinois Predatory Loan Prevention Act signed into law and now effective

Ballard Spahr LLP on

On March 23, Illinois Governor Pritzker signed into law SB 1792, which contains the Predatory Loan Prevention Act (the “Act”).  The new law became effective immediately upon signing notwithstanding the authority it gives the...more

Goodwin

Illinois Imposes 36% MAPR Rate Cap On Consumer Loans; Takes Aim At Fintech-Bank Partnerships And Secondary Market Transactions

Goodwin on

On March 23, 2021, the Predatory Loan Prevention Act (the “PLPA”) was signed into law by Illinois Governor J.B. Pritzker. The PLPA imposes a 36% military annual percentage rate (“MAPR”) cap on all loans made to Illinois...more

Troutman Pepper

Fintechs Beware! The CFPB is Monitoring You Closely

Troutman Pepper on

On March 18, Opportunity Financial, Inc. (OppFi) — a Chicago-based platform lender — announced that the Consumer Financial Protection Bureau (CFPB) is investigating its compliance with the Military Lending Act. The...more

Morrison & Foerster LLP

Financial Services Report - Spring 2021

Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more

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