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Regulation Z

Ballard Spahr LLP

CFPB Issues Guidance on Consideration of Immigration Status Based on Ability to Repay Requirements Without Providing Sufficient...

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When the CFPB and Department of Justice withdrew a joint statement on the consideration of immigration status under the Equal Credit Opportunity Act in January 2026, we pointed out that “the agencies could have, but did not,...more

Thompson Coburn LLP

Private Loans, Preferred Lender Arrangements, and Prohibited Inducements are Back!

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In the spring of 2007, New York’s Attorney General initiated a high-profile investigation into what he characterized as unethical conduct across the student loan industry....more

Troutman Pepper Locke

President Trump Issues Executive Order 14406 to Restore Integrity to America’s Financial System

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On May 19, President Donald Trump issued Executive Order 14406, “Restoring Integrity to America’s Financial System,” which establishes a new policy to safeguard financial institutions against structural credit risks and deter...more

Husch Blackwell LLP

Following the Rules While Minding the Funding Gap: Private Student Lending and Preferred Lender Arrangement Requirements

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The One Big Beautiful Bill Act has dramatically reshaped the higher education funding landscape by scrapping the Graduate PLUS program, capping annual borrowing for students and parents, and imposing a lifetime limit for...more

Cooley LLP

FDIC Issues 2026 Consumer Compliance Supervisory Highlights

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The FDIC recently published its annual Consumer Compliance Supervisory Highlights, covering examination results and consumer complaint trends for FDIC-supervised state-chartered banks and thrifts that are not members of the...more

Bradley Arant Boult Cummings LLP

The Post-Dodd-Frank Rollback Begins? New Executive Order Targets Mortgage Origination, Servicing, and Reporting Rules

On March 13, 2026, President Trump signed an executive order titled “Promoting Access to Mortgage Credit,” directing federal financial regulators to consider a broad set of revisions to the mortgage regulatory framework....more

Alston & Bird

Executive Order Targets Smaller Bank Participation in Mortgage Markets

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What Happened? On March 13, President Trump issued an Executive Order titled “Promoting Access to Mortgage Credit,” addressing factors that may have negatively impacted the ability of community banks and other smaller...more

McDermott Will & Schulte

New York proceeds with expansive regulation of buy now, pay later products

On February 23, 2026, the New York State Department of Financial Services (NYDFS) published a proposed regulation (the Proposed Regulation) implementing the state’s Buy Now, Pay Later (BNPL) Act, which was signed into law by...more

Cooley LLP

Executive Order Seeks to Expand Mortgage Credit for Customers of Community and Smaller Banks

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On March 13, 2026, the White House issued an executive order that directs the Consumer Financial Protection Bureau (CFPB) and federal housing and banking agencies to consider a series of mortgage-related regulatory and...more

Ballard Spahr LLP

CRS says policymakers are facing myriad of BNPL issues

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Although an interpretive rule that made Buy Now Pay Later (BNPL) services subject to the Truth in Lending Act has been withdrawn, the issue remains a flashpoint in the industry and among policymakers, according to the...more

Venable LLP

NYDFS Proposes Comprehensive Rules for Buy Now, Pay Later Lenders

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New York is moving to establish a dedicated licensing and consumer-protection regime for Buy Now, Pay Later (BNPL) products. The New York legislature enacted the Buy Now Pay Later Act (Article 14-B of the New York Banking...more

BCLP

New York's Proposed Regulations for Buy Now, Pay Later Consumer Finance Services

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Buy-now, pay-later plans have seen rapid and widespread popularity among consumers and retailers. Acting in a perceived regulatory vacuum at the federal level, New York has adopted legislation to protect consumers as part of...more

Sheppard

Florida District Court Upholds CFPB’s Residential PACE Rule

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On February 12, the U.S. District Court for the Middle District of Florida upheld the CFPB’s final rule applying mortgage-style requirements to Residential Property Assessed Clean Energy (PACE) financing, rejecting a trade...more

Hudson Cook, LLP

Consumer Financial Services Bites of the Month - January 2026 - "It's Not a Hot Day in January."

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In this month's article, we share some of our top "bites" covered during the January 2026 webinar....more

Husch Blackwell LLP

Mark Your Calendars: 2026 Compliance Dates for Consumer and Small Business Financial Services

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Welcome to 2026! As we begin another year in the fast-evolving world of consumer financial services regulation, we're here with our annual roadmap of key compliance dates to help you plan ahead. Whether you're in mortgage...more

Goodwin

FinCEN Issues Final Rule to Postpone Effective Date of Investment Adviser Rule to 2028

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Welcome to Goodwin’s Financial Services News Roundup. Our newsletter highlights important legal, regulatory, and business developments related to financial services and banking....more

Goodwin

CFPB Says Some Earned Wage Access Products Not Considered Credit

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On December 23, 2025, the CFPB issued an advisory opinion stating that “covered” earned wage access (EWA) products fall outside the definition of credit under TILA’s Regulation Z, withdrawing a Biden Administration July 2024...more

Hudson Cook, LLP

CFS Bites of the Month - 2025 Annual Review - Mortgage

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In this article, we share a timeline of monthly "bites" for the past year applicable to Mortgage....more

K&L Gates LLP

To Z or Not to Z? CFPB Clarifies the Regulation Z Treatment of Certain Earned Wage Access Products

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The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion (the 2025 Opinion), effective 23 December 2025, on whether earned wage access (EWA) products constitute “credit” under Regulation Z of the Truth in...more

Goodwin

CFPB Brings Clarity to Earned Wage Access Products

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The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion on December 23, 2025, that resolves significant regulatory uncertainty surrounding whether earned wage access (EWA) products and are “credit” for...more

Orrick, Herrington & Sutcliffe LLP

CFPB issues advisory opinion on the applicability of Regulation Z to earned wage access products

On December 23, the CFPB issued an advisory opinion in the Federal Register clarifying the regulatory treatment of earned wage access (EWA) products under Regulation Z, as implemented by TILA. ...more

Orrick, Herrington & Sutcliffe LLP

CFPB updates asset-size exemption thresholds under TILA and HMDA

On January 7, the CFPB amended the official commentary to Regulation Z (which implements TILA) and Regulation C (which implements the HMDA) by updating the asset-size exemption thresholds for financial institutions. These...more

Wiley Rein LLP

Wiley Consumer Protection Download (January 6, 2026)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Federal Trade Commission (FTC), the Consumer Financial Protection Bureau (CFPB), and the state level. Check out our new State...more

Ballard Spahr LLP

CFPB Adjusts HPML Asset Exemption Threshold (UPDATED)

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The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML). Regulation Z, which...more

Morrison & Foerster LLP

CFPB Reestablishes Position That Certain Earned Wage Access Programs Are Not “Credit”

On December 23, 2025, the Consumer Financial Protection Bureau (CFPB or “Bureau”) published an advisory opinion (the “2025 EWA Advisory Opinion”) concluding that certain earned wage access (EWA) programs do not constitute...more

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