News & Analysis as of

Non-Bank Lenders Rulemaking Process

Sheppard Mullin Richter & Hampton LLP

Reminder: FTC Safeguards Rule Notification Requirement Now In Effect

On May 13, the FTC’s amendment to the Safeguards Rule relating to the reporting of data breaches and security incidents, which were announced in October of 2023, became effective. As a reminder, the FTC’s Safeguards Rule...more

Sheppard Mullin Richter & Hampton LLP

CFPB Publishes New Report on State Community Reinvestment Laws

On November 2, the CFPB issued a new report on state Community Reinvestment Act laws. The report found that many states adopted Community Reinvestment Acts (CRAs) similar to the federal Community Reinvestment Act of 1977. The...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes Registry of Terms and Conditions for Nonbanks

On January 11, the CFPB proposed a rule requiring nonbanks subject to its supervisory authority, with limited exceptions, to annually register with the CFPB regarding their use of certain terms and conditions in form...more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes T&C registry for nonbanks

On January 11, the CFPB announced a proposed rule to create a public registry of terms and conditions used in non-negotiable, “take it or leave it” nonbank form contracts that “claim to waive or limit consumer rights and...more

Hudson Cook, LLP

CFPB Bites of the Month - Carving Up the CFPB

Hudson Cook, LLP on

In this month's Top 10 article, we share some of our top "bites" for the prior month covered during the November 16, 2022 webinar. So, what happened last month? Extra Bite: CFPB Releases Report on Tenant Background...more

Ballard Spahr LLP

OCC issues proposed “true lender” rule

Ballard Spahr LLP on

Less than two months after issuing its final “Madden fix” rule, the OCC has now issued a proposed rule to address when a national bank or federal savings association should be considered the “true lender” in the context of a...more

Ballard Spahr LLP

DoD to propose amendment to MLA regulations on auto financing

Ballard Spahr LLP on

The Department of Defense announced in its Fall 2019 rulemaking agenda that it is engaged in proposed rulemaking to amend its Military Lending Act (MLA) regulations, apparently in order to allow non-bank creditors to provide...more

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