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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.

The CFPB (Yes, the CFPB!) Offers New Compliance Tools for InnovationCompanies that offer innovative consumer financial products and services have new tools to help them stay in compliance with federal consumer financial laws. In a refreshing twist from prior policy, the Consumer Financial Protection Bureau (CFPB) announced last week that it had revamped its No-Action Letter Policy and released a Compliance Assistance Sandbox and a

CFPB Guts Major Component of Payday Lending RuleToday, the CFPB proposed amendments to its Payday, Vehicle Title, and Certain High-Costs Installment Loans Rule. As anticipated, the bureau is proposing to rescind the rule’s requirements that lenders make certain ability-to-repay underwriting determinations before issuing payday, single-payment vehicle title, and longer-term balloon payment loans on the basis that such restrictions would limit consumer access

CFPB Proposes Reporting and Examination Authority Over Military Lending ActThe Consumer Financial Protection Bureau on January 17, 2019, asked Congress to grant the bureau clear authority to supervise compliance-related issues for the Military Lending Act. CFPB Director Kathy Kraninger transmitted a legislative proposal to the speaker of the U.S. House of Representatives and Vice President Pence in his capacity as president of the U.S.

Court Stays Compliance Date for BCFP’s Payday RuleOn Tuesday, the small-dollar lending industry received a favorable ruling in Community Financial Services Association of America v. CFPB. A Texas federal court reversed course by staying the August 19, 2019, compliance date for the Bureau of Consumer Financial Protection’s (BCFP) rule regarding “Payday, Vehicle Title, and Certain High-Costs Installment Loans.” The court also

BCFP Enters into Consent Order with Small Dollar LenderOn October 24, 2018, the Bureau of Consumer Financial Protection (BCFP), formerly known as the CFPB, entered into a Consent Order with Cash Express, LLC. Cash Express is a small dollar lender based in Cookeville, Tennessee, that operates 328 retail lending outlets in Alabama, Kentucky, Mississippi, and Tennessee, and offers short-term loans and check cashing

OCC: Fintechs May Now Apply for Bank ChartersThe Office of the Comptroller of the Currency announced, in a highly anticipated decision, that it would begin to consider special-purpose charter applications from fintech entities. This move, which has been the subject of months of industry speculation, came mere hours after the Department of the Treasury endorsed a national charter for fintech companies.