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 18, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a set of frequently asked questions (FAQs) providing guidance on applying Regulation Z requirements to Pay-in-Four Buy Now, Pay Later (BNPL)...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
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
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
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
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
Welcome to the Fintech chapter of our annual report Consumer Financial Services 2023 Year in Review. Looking Ahead to 2024 - The CFPB is expected to finalize rulemaking authorizing supervision of payment application...more
The American Fintech Council (AFC), a trade group whose members include providers of earned wage access (EWA) products, has sent a letter to Director Chopra urging the CFPB to take steps towards development of a “pragmatic...more
The Consumer Financial Protection Bureau has sent a letter to the California Department of Financial Protection and Innovation (DFPI) commenting on the DFPI’s proposal that would require providers of “income-based advances”...more
Last month, the CFPB released new Supervisory Highlights identifying examinations findings in the areas of auto servicing, consumer reporting, credit card account management, debt collection, deposits, mortgage origination,...more
We recently wrote about the Consumer Financial Protection Bureau's November 2020 advisory opinion regarding earned wage access (EWA) programs. In that opinion, the CFPB determined that earned wage access programs — when...more
Last week, we reported that on December 30, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued compliance assistance sandbox (“CAS”) approval to Payactiv, Inc. (“Payactiv”) regarding specific aspects...more
On November 30, 2020, the Consumer Financial Protection Bureau released an advisory opinion concerning earned wage access ("EWA") products. The opinion was released as a sort of "launch day bonus" for the release of the...more
On December 30, 2020, the Consumer Financial Protection Bureau (“CFPB”) granted approval to Payactiv, Inc. (“Payactiv”) to offer its earned wage access (“EWA”) program under the CFPB’s Policy on the Compliance Assistance...more
The CFPB has published its Fall 2020 rulemaking agenda as part of the Fall 2020 Unified Agenda of Federal Regulatory and Deregulatory Actions. It represents the CFPB’s fourth rulemaking agenda under Director Kraninger’s...more
The CFPB has published its Spring 2020 rulemaking agenda as part of the Spring 2020 Unified Agenda of Federal Regulatory and Deregulatory Actions. It represents the CFPB’s third rulemaking agenda under Director Kraninger’s...more
On February 14, 2020, the Consumer Financial Protection Bureau (CFPB) released its Winter 2020 Supervisory Highlights (Report). It summarizes the CFPB’s findings on violations in the areas of debt collection, mortgage...more
The CFPB announced that it has entered into a settlement with the owners of payday loan retail outlets that operated under the name “Cash Tyme” in seven states to resolve alleged violations of the Consumer Financial...more
The Federal Trade Commission has provided its annual Financial Acts Enforcement Report to the CFPB covering the FTC’s enforcement activities in 2016 relating to compliance with Regulation Z (Truth in Lending Act), Regulation...more
At the meeting earlier this month of the American Bar Association’s Consumer Financial Services Committee in Carlsbad, CA, attention was given to an issue highlighted by the American Bankers Association in the comment letter...more
On June 30, 2016, the Consumer Financial Protection Bureau (“CFPB”) released the twelfth edition of its Supervisory Highlights report (“Report”), which focused on supervision work completed between January and April 2016. The...more
The Federal Trade Commission (FTC) has provided its annual report to the Consumer Financial Protection Bureau (CFPB) covering the FTC’s enforcement activities in 2015 related to compliance with Regulation Z (Truth in...more
The Federal Trade Commission has provided its annual report to the CFPB covering the FTC’s enforcement activities in 2015 related to compliance with Regulation Z (Truth in Lending), Regulation M (Consumer Leasing), and...more
On July 22, 2015, the Department of Defense (DOD) published sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more
The Department of Defense (DoD) dramatically expanded the scope of the Military Lending Act (MLA) on July 22, 2015, publishing its Final Rule amending the MLA’s implementing regulation. MLA coverage was previously limited to...more