News & Analysis as of

Regulation Z Payday Loans Consumer Lenders

Nelson Mullins Riley & Scarborough LLP

Who is Paying Who: The Employee or the Employer?

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

Ballard Spahr LLP

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

Ballard Spahr LLP on

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

Sheppard Mullin Richter & Hampton LLP

CFPB Fall Supervisory Highlights Find Credit Reporting Failures, Junk Fees, Mishandling of Covid-19 Protections

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

Ballard Spahr LLP

FTC Provides 2016 Enforcement Report to CFPB

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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

Ballard Spahr LLP

ABA highlights error in cost of credit calculation method used in CFPB’s proposed payday loan rule

Ballard Spahr LLP on

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

Davis Wright Tremaine LLP

Revised Military Lending Act Rules Impose New Compliance Obligations on a Wide Variety of Creditors

The Department of Defense (DOD) recently finalized amendments to its Military Lending Act (MLA) regulations that impose new compliance obligations on a wide variety of creditors, including issuers of credit cards and...more

Ballard Spahr LLP

Defense Department Dramatically Expands Scope of Military Lending Act

Ballard Spahr LLP on

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

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