News & Analysis as of

Usury Subprime Loans

Miller Canfield

Commitment Fees Might Constitute Interest Under Michigan Law

Miller Canfield on

Lenders often include fees in loan transactions in addition to an interest rate. Typically such fees are not considered interest, as they compensate the lender for various services or commitments provided under the loan...more

White & Case LLP

Consumer financial services: The road ahead: Small-dollar loans

White & Case LLP on

In February 2019, the CFPB released the highly anticipated revamp of its Payday Rule, reinforcing its more lenient attitude towards payday lenders. In light of the Bureau’s softer touch, as well as similar developments at the...more

Ballard Spahr LLP

OCC small dollar lending bulletin gets mixed reviews from consumer advocates

Ballard Spahr LLP on

The bulletin issued this week by the OCC encouraging the banks it supervises “to offer responsible short-term, small-dollar installment loans” quickly met with mixed reviews from consumer advocates....more

Goodwin

Massachusetts and Delaware AGs Announce $25 Million in Settlements with Subprime Auto Lender

Goodwin on

On March 29, 2017, the Massachusetts and Delaware Attorney Generals (“AGs”) announced settlements with a national bank, resolving allegations that the bank originated unfair and usurious automobile loans in violation of...more

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