On November 13, the CFPB and the Fed released updated dollar thresholds for whether certain credit and lease transactions are subject to Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) requirements for...more
On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more
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
On September 11, 2023, the CFPB filed an administrative consent order against a Nonbank Consumer Finance Company, with its principal place of business in Manchester, New Hampshire. The order alleges that the Company concealed...more
The Federal Trade Commission has provided its annual report to the CFPB on its enforcement and related activities in 2022 regarding the Truth in Lending Act (TILA), Consumer Leasing Act (CLA), and Electronic Fund Transfer Act...more
In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed rules to include certain significant market participants as “dealers” or “government securities dealers” to essentially eliminate the trader exclusion...more
A lot of lawyers are afraid of numbers, but I'm one of the strange ones who enjoys handling the mathematical aspects of financial services law. To a lawyer like me, the beauty of a credit or lease contract is that if you've...more
In the News. The Office of the Comptroller of the Currency (OCC) issued a long-awaited rule seeking comment on its proposed approach to determine the Community Reinvestment Act (CRA) evaluation measure benchmarks, retail...more
The Federal Trade Commission recently provided its annual letter to the CFPB concerning its enforcement activities relating to compliance with Regulation Z (Truth in Lending Act), Regulation M (Consumer Leasing Act), and...more
Federal Banking Agencies Propose Alternative Capital Framework for Community Banks - The federal banking agencies have proposed a new community bank leverage ratio (“CBLR”) framework that would simplify regulatory capital...more
The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments....more
Federal Banking Agencies Issue New Guidance for Banks Affected by a Major Disaster - The federal banking agencies have jointly issued new guidance on the supervisory practices to be followed in assessing the financial...more
The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2018 through...more
The Federal Trade Commission (FTC) has filed an action against nine auto dealerships and their individual owners in a California federal court that the FTC described as its "first action against an auto dealer for 'yo-yo'...more