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Jennifer Galloway’s practice is dedicated to helping financial services clients successfully navigate increasingly complex regulatory and business environments. She is co-chair of Bradley’s Small Dollar and Unsecured Consumer Lending team and focuses on consumer financial services laws and regulations affecting banks, non-depository banks and other financial institutions. Jennifer provides skilled regulatory guidance and detailed knowledge of the laws impacting both traditional and innovative lenders in the consumer financial services market, with considerable experience in online consumer lending. Her compliance work includes assisting clients with developing, implementing and maintaining compliance management systems, performing internal compliance audits for clients, preparing clients for outside audits, as well as preparing related lending documents and disclosures. She also counsels financial services companies regarding CFPB preparedness, implementation and operational strategies for complying with the CFPB's regulations, and assists in defending regulatory enforcement actions.

On Monday, the CFPB issued a press release announcing that it will start using its authority to examine non-bank financial services institutions that the CFPB has “reasonable cause to determine pose risks to consumers.” In addition, the CFPB has released a procedural rule designed to “increase transparency of the risk-determination process” by subjecting the results

Beginning next year, New Mexico will join a handful of other states (including, among others, California, Illinois, and Colorado) setting stringent interest rate caps on consumer loans. House Bill 132, which Gov. Michelle Lujan Grisham signed on March 1, 2022, will slash the annual percentage rate (APR) applicable to loans made under New Mexico’s

CFPB Fall Supervisory Highlights Shed Light on Agency Priorities – Small Dollar LendingThe Fall Supervisory Highlights came out this month and reports the Bureau’s findings of examinations completed between January 2021 and June 2021. The CFPB publishes the Supervisory Highlights to help institutions better understand how the CFPB examines and monitors compliance with federal consumer financial laws. CFPB examiners often find problems during supervisory examinations that are

After (Another) Unusual Year, We’re Very Thankful and Wish You a Happy ThanksgivingNow that the pandemic’s “social distancing” is lessening, we hope you are all able to gather with friends and family this Thanksgiving. As we do the same, we wanted to count our blessings as we review the year. This year, we are thankful for being able to return to our offices, our favorite restaurants, and

District Court Ruling Clears Way for Small Dollar Rule Compliance Date in June 2022Yesterday, in Community Financial Services Association of America, Ltd. v. Consumer Financial Protection Bureau, a lawsuit involving implementation of the payment provisions of the Payday, Vehicle Title, and Certain High-Cost Installment Loans Regulation (the “Small Dollar Rule”), the district court ruled on the Consumer Financial Protection Bureau’s (CFPB) and the Community Financial Services Association’s

The CFPB at 10 Years: A Look Back and a Look AheadOver the years, we have followed actions of the Consumer Financial Protection Bureau (CFPB) and published information that can be found on our Financial Services Perspectives blog. Now that the 10-year anniversary of the CFPB opening its doors has passed, let’s take a look back at where it started and where it may be

Illinois Caps Consumer Loans at 36% Rate, Limiting Consumers’ Access to CreditLast week, Illinois enacted the “Predatory Loan Prevention Act” (SB 1792), which would place a 36% rate cap on nearly all non-bank consumer loans. This act will essentially outlaw small-dollar loans in Illinois and may make ancillary products on auto loans, such as GAP insurance, unavailable for a large number of consumers. The act

The Consumer Financial Protection Bureau Issues Statement Regarding Small Dollar Lending and Signals Return to Prior PolicyOn March 23, 2021, the CFPB issued a brief statement highlighting its position regarding “consumer harms in the small dollar lending market” and likely future action to reverse the previous CFPB administration’s policy regarding the industry. The next day, the CFPB provided its Consumer Response Annual Report for 2020 to Congress, which stated the complaint

In the Strangest Year Ever, We’re Very Thankful and Wish You a Happy Thanksgiving

As everyone steps away from their (home) office to celebrate Thanksgiving, we wanted to count our blessings as we review this truly remarkable and unusual year. In addition to frontline healthcare workers, good WI-FI, food delivery services, and finally finding a mask that is comfortable, we are also thankful for the following:

1. The CARES

New FAQ Responses to Small Dollar Rule Address Auto and Mortgage Lending, Payment Transfers and Notices InclusionOn Tuesday, August 11, 2020, the CFPB issued a second round of answers to frequently asked questions related to the Small Dollar Rule. The FAQ responses range from addressing more nuanced provisions of the payment provision portion of the rule to the overall coverage of the rule.

Covered Loan Coverage

For the most part, auto