On December 16, the CFPB announced that it had issued orders to five companies providing “Buy Now Pay Later” (BNPL) products to “collect information on the risks and benefits of these fast-growing loans.” Earlier this year, the CFPB released a blog directed at consumers explaining how BNPL products operate and identifying potential risks associated with
The CFPB Director Expresses Concern About Section 1071 Regulatory Burdens on Small Banks
After the Consumer Financial Protection Bureau (CFPB) issued their Notice of Proposed Rulemaking (NPRM) related to Dodd-Frank 1071, Rohit Chopra, the new CFPB director, expressed his concern regarding the regulatory burden that the proposed rule would have on small banks. Director Chopra stated that he hoped the CFPB could move towards bright-lined rules that are
CFPB Sets Its Sights on Tech Companies
In one of his first actions since being sworn in as director of the Consumer Financial Protection Bureau (CFPB), Rohit Chopra has made clear that the CFPB will be looking over the shoulder of large technology companies to protect consumers.
Director Chopra comes to the CFPB directly from his stint as a commissioner at the
New York DFS Proposes Regulation to Implement TILA-Like Requirements on Small Business Loans
On September 21, 2021, New York’s Department of Financial Services (DFS) announced proposed regulations that clarify the small business Truth in Lending disclosure requirements that go into effect on January 1, 2022. The proposed regulations come just in time as non-banks and fintechs are attempting to prepare to comply with the commercial financing law with
CFPB Issues NPRM on Dodd-Frank 1071; Bradley to Host Initial Webinar on September 8
Yesterday, the Consumer Financial Protection Bureau (CFPB) issued its long-awaited Notice of Proposed Rulemaking (NPRM) related to Dodd-Frank 1071. As we have discussed in this space, Section 1071 amends the Equal Credit Opportunity Act to mandate certain reporting requirements for financial services companies making business loans. The act aims to “facilitate enforcement of fair
District Court Ruling Clears Way for Small Dollar Rule Compliance Date in June 2022
Yesterday, 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
What the Proposed North Carolina Regulatory Sandbox Could Mean for Fintech and the Financial Services Community
Technology is booming and financial technology (“fintech”) is advancing society in new and innovative ways. In 2021 alone, North Carolina has been the target for some very high-profile technology announcements, including Google’s plans to open a cloud engineering hub in Durham and Apple’s new campus in Research Triangle Park. Given the upward trajectory of this
CFPB Signals Continued Progress Toward Dodd-Frank 1071 Notice of Proposed Rulemaking
On the heels of CFPB Acting Director Dave Uejio’s recently released statement to agency staff members, the Bureau again signaled that it is making progress toward issuing a Notice of Proposed Rulemaking (NPRM) enacting Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act). Specifically, in late February, the CFPB
Illinois Caps Consumer Loans at 36% Rate, Limiting Consumers’ Access to Credit
Last 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
Acting CFPB Director Uejio Reiterates Commitment to Issuing Regulations Enacting Dodd-Frank 1071
On February 4, 2021, acting CFPB Director Dave Uejio published a blog post sharing statements recently made to the staff of the CFPB’s Division of Research, Markets, and Regulations (RMR). In his post, Uejio stressed two policy priorities for the CFPB: “(1) relief for consumers facing hardship due to COVID-19 and the related economic crisis