News & Analysis as of

Truth in Lending Act (TILA) Credit

Ballard Spahr LLP

NCLC Asks CFPB to Consider Residential Leases as Credit for Specific Purposes

Ballard Spahr LLP on

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

McGlinchey Stafford

Credit, Tips, Obligation to Pay: CFPB Proposed Interpretive Rule Seeks to Clarify Earned Wage Access and Regulation Z

McGlinchey Stafford on

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

Davis Wright Tremaine LLP

CFPB Takes Aim at Earned Wage Access Products as Regulated Loans

The Consumer Financial Protection Bureau (CFPB) proposed an interpretive rule that would extend Truth in Lending Act (TILA) and Regulation Z (Reg Z) compliance requirements to many existing earned wage access (EWA) products....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 Proposes Interpretive Rule Characterizing Earned Wage Access Products as Loans

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

Troutman Pepper

CFPB Says Earned Wage Access Products are Subject to the Truth in Lending Act

Troutman Pepper on

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

Cadwalader, Wickersham & Taft LLP

Consumer Credit and Leasing Thresholds Updated for 2023

For purposes of general applicability of the Truth in Lending Act and Regulation Z to credit transactions and the Consumer Leasing Act and Regulation M for lease transactions, the Consumer Financial Protection Bureau ("CFPB")...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

Ballard Spahr LLP on

The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

Troutman Pepper on

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

Hudson Cook, LLP

Income Share Agreements - Operating Under Current Regulations and Preparing for the Future

Hudson Cook, LLP on

The Income Share Agreement ("ISA") market is rapidly developing with more providers offering ISA programs to students and outside money moving into the space. However, the legal environment remains uncertain, and providers...more

Hudson Cook, LLP

Still Beating the Same Drum

Hudson Cook, LLP on

In February, the U.S. PIRG Education Fund and Frontier Group, two public interest groups, published a paper entitled "Driving Into Debt: The Hidden Costs of Risky Auto Loans to Consumers and Our Communities." The paper...more

Morrison & Foerster LLP

Financial Services Report, Summer 2016

BELTWAY - Every Last Penny Counts - Five federal banking agencies issued a Supervisory Bulletin titled “Interagency Guidance Regarding Deposit Reconciliation Practices” (the “Guidance”). The Guidance outlines...more

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