Consumer Finance Monitor Podcast Episode: Buy Now, Pay Later – Evolution, Regulation, and What You Need to Know about the CFPB Interpretive Rule Effective July 30
CFPB's New Interpretive Rule: Buy Now, Pay Later as Credit Cards — The Consumer Finance Podcast and Payments Pros Podcast
An In-Depth Analysis of the CFPB's Proposed Overdraft Rule — Payments Pros – The Payments Law Podcast
An In-Depth Analysis of the CFPB’s Proposed Overdraft Rule - The Consumer Finance Podcast
Exploring the Future of Open Banking: A Discussion on CFPB's 1033 Proposed Rule – Crossover Episode With Regulatory Oversight Podcast – The Consumer Finance Podcast
On September 13, 2024, the CFPB filed a lawsuit against the company and its owner and CEO, alleging deceptive and abusive acts and practices in violation of the CFPA and violations of TILA and its implementing regulation....more
Paycheck advance products that are deemed consumer loans under the CFPB’s new proposal would be subject to increased disclosure and regulatory protections....more
The National Consumer Law Center is asking the CFPB, by way of a petition, for rulemaking that is long on policy arguments but woefully short on legal support, as we note below, to define residential leases as “credit” under...more
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued notice of a proposed interpretive rule (Rule) that walks back a prior 2020 Advisory Opinion on the manner in which Regulation Z defines “credit.” The...more
On August 16th, the Consumer Financial Protection Bureau ("CFPB") Director, Rohit Chopra, published a blog post entitled “What Buy Now, Pay Later lenders are doing to be upfront with borrowers” that follows up on its proposed...more
On August 13, 2024, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion stating that contracts for deed are “credit” under Regulation Z, and therefore subject to its myriad requirements. Unlike a...more
The Introduction to the Complaint which was filed by the CFPB on May 17, 2024 against Solo Funding, Inc. in the United States District Court for the Central District of California – Western Division Los Angeles (Judge R. Gary...more
On August 13, the CFPB released an advisory opinion regarding home purchases under a “contract for deed” and how the purchases must comply with federal mortgage protections. The advisory opinion stated the contract for deed...more
This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion and a research report addressing contract-for-deed home financing, also known as a “land contract,” “land installment contract,”...more
We have recently blogged about two other actions in which this issue has been raised (one being a declaratory judgment action filed against the CFPB on July 23, 2024 in the E.D. Tex. and the other being an enforcement action...more
Earned wage access (“EWA”) programs are financial products that allow workers to receive payment for wages they have already earned before their next scheduled payday. Many of these programs are integrated into their...more
On July 17, 54 members of the Congressional Progressive Caucus sent a letter addressed to the Speaker of the U.S. House of Representatives, Mike Johnson, discussing the upcoming House consideration of H.J. Res. 122 (the...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
To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...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
“Buy Now, Pay Later” (BNPL) products emerged relatively recently as a new approach enabling consumers to enjoy the ability to make a purchase and then pay for it over time. Today’s episode, during which we explore the...more
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a proposed Interpretive Rule addressing the regulatory treatment of earned wage access (EWA) products. The Interpretive Rule would provide that certain...more
Late last week, the Consumer Financial Protection Bureau (CFPB) released a proposed interpretive rule asserting that paycheck advance or earned wage access (EWA) products are considered consumer loans and therefore subject to...more
On July 18, the CFPB proposed a new interpretive rule that would characterize earned wage access (“EWA”) products as extensions of credit and subject to the Truth in Lending Act and Regulation Z. Under the interpretive...more
Last week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed interpretive rule opining that earned wage access (EWA) products — whether provided through employer partnerships or marketed directly to...more
On July 9, 2024, the Consumer Financial Protection Bureau (CFPB) announced that it filed a proposed stipulated final judgment and order in its suit against a national bank accused of allegedly opening unauthorized accounts...more
In an unusual move, the CFPB is coming to the defense of a bank being accused of failing to provide repayment disclosures to a borrower....more
In this special crossover episode of The Consumer Finance Podcast and Payments Pros Podcast, Chris Willis and Josh McBeain interview two colleagues who delve into the Consumer Financial Protection Bureau’s (CFPB) recent...more
The U.S. Department of Veterans Affairs (VA) recently proposed rules under its home loan guaranty program regarding adjustable rate mortgage (ARM) loans, hybrid ARM (h-ARM) loans and temporary buydown agreements. Comments are...more
On May 28, the Federal Trade Commission (FTC) released its annual report to the Consumer Financial Protection Bureau (CFPB) detailing enforcement and educational activities undertaken in 2023. The report pertains to actions...more