News & Analysis as of

Truth in Lending Act (TILA) Public Comment

Latham & Watkins LLP

CFPB Proposes to Designate Earned Wage Access Products as Loans

Latham & Watkins LLP on

Paycheck advance products that are deemed consumer loans under the CFPB’s new proposal would be subject to increased disclosure and regulatory protections....more

Orrick, Herrington & Sutcliffe LLP

CFPB proposes an interpretive rule for earned wage access

On July 18, the CFPB proposed an interpretive rule to clarify that many paycheck advance products, or "earned wage" products, were consumer loans and therefore subject to TILA. The CFPB seeks to require lenders to provide...more

Nutter McClennen & Fish LLP

Nutter Bank Report: January 2024

OCC Requests Public Comments on Proposed Bank Merger Policy Statement and Rules The OCC has proposed a new policy to increase the transparency of the standards that the agency applies to review business combinations involving...more

Miles & Stockbridge P.C.

CFPB Considers Whether TILA Preempts State Commercial Finance Disclosure Laws, Requests Public Comment

A number of states have enacted laws requiring consumer-like disclosures in certain commercial financing transactions. These state statutes resemble the Truth in Lending Act (TILA) in certain respects but apply only to...more

Goodwin

Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial...

Goodwin on

Regulatory Developments - Federal Reserve Invites Public Comment on Proposed Principles for Large Banking Organizations to Manage Climate-Related Financial Risks - On December 2, the Federal Reserve announced that it...more

Venable LLP

The Buy-Now-Pay-Later Boom Gets Consumer Protection Attention

Venable LLP on

The explosion in Buy-Now-Pay-Later (BNPL) has caught the eyes of lawmakers and regulators, who are taking a closer look at this booming industry. BNPL payment offers allow consumers to purchase goods or services now and...more

Eversheds Sutherland (US) LLP

Focus on Fintech: The CFPB is Scrutinizing Buy Now Pay Later Products - is Rulemaking Next?

The “buy now pay later” (BNPL) market continued its trend of increasing valuations and consumer uptake through the end of 2021. BNPL’s popularity is largely due to its simple repayment terms and low cost relative to...more

Goodwin

Supreme Court Decision Empowers President Biden to Replace Director of FHFA

Goodwin on

In This Issue. In a move that gives him the opportunity to put his stamp on housing policy and the potential overhaul of Fannie Mae and Freddie Mac, President Biden replaced the Director of the Federal Housing Finance Agency...more

Goodwin

SEC Charges Trust Company With Operating Unregistered Investment Companies

Goodwin on

SEC Charges Trust Company with Operating Unregistered Investment Companies and Failing to Register Securities Offerings. On September 30, the Securities and Exchange Commission (SEC) announced it had settled charges with...more

Goodwin

CFPB Proposes New “Seasoned” Qualified Mortgage Category

Goodwin on

On August 18, 2020, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule to create a new category of loans known as “seasoned” qualified mortgages (Seasoned QMs). This new category of qualified mortgages...more

White & Case LLP

Consumer financial services: The road ahead: Payment processing

White & Case LLP on

The CFPB continued to be active in the consumer payments space in 2018, while the Federal Reserve and market participants considered the future of payment processing, including the development of faster payment systems....more

Baker Donelson

CFPB Seeking Public Comment on Proposed Amendments to 2013 Mortgage Rules

Baker Donelson on

The CFPB is currently seeking public comment on several proposed amendments to its final rules issued in 2013, which went into effect in January 2014. The comment period is open through March 16, 2015, so mortgage servicers,...more

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