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Aug 7, 2024 | 
jdsupra.com | Scott Pearson |Bryan Schneider
Earned wage access (“EWA”) programs are financial products that allow workers to receive payment for wages they have already earned before their next scheduled payday. Many of these programs are integrated into their employers’ payroll systems, while others are offered through direct-to-consumer marketing. They do not impose mandatory fees on consumers and have not been the subject of significant consumer complaints.
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Jun 3, 2024 | 
mondaq.com | Bryan Schneider |Eric Knight |Scott Pearson
To the likely surprise of providers of buy now, pay later
("BNPL") financing, last week the Consumer Financial
Protection Bureau ("CFPB") issued an interpretive rule stating that BNPL products
are actually "credit cards" under the Truth in Lending
Act (TILA) and BNPL providers are "card issuers" and
therefore "creditors" under, and subject to, Regulation
Z.
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May 31, 2024 | 
jdsupra.com | Eric Knight |Scott Pearson |Bryan Schneider
To the likely surprise of providers of buy now, pay later (“BNPL”) financing, last week the Consumer Financial Protection Bureau (“CFPB”) issued an interpretive rule stating that BNPL products are actually “credit cards” under the Truth in Lending Act (TILA) and BNPL providers are “card issuers” and therefore “creditors” under, and subject to, Regulation Z.
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May 6, 2024 | 
jdsupra.com | Scott Pearson |Bryan Schneider
On April 24, 2024, the Consumer Financial Protection Bureau (CFPB) continued its assault on fees in the consumer finance industry.
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Feb 21, 2024 | 
jdsupra.com | Scott Pearson |Bryan Schneider
What HappenedOn February 16, 2024, the Consumer Financial Protection Bureau (CFPB) issued a procedural rule revising its supervisory appeals process for the first time since 2015. This Rule makes several important changes: Under the Rule, any CFPB manager who did not participate in the underlying supervisory matter and who is familiar with the topic may be assigned to a supervisory appeals committee, rather than only managers in the Supervision division, as had been the case previously.
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Nov 19, 2023 | 
mondaq.com | Scott Pearson |Bryan Schneider |Eric Knight
On October 26, a Texas District Court issued an expanded injunction preventing the CFPB
from implementing and enforcing its small-business data collection rule issued under Section 1071
of the Dodd-Frank Act, so that it now benefits all companies
subject to the rule. The Court's prior injunction, issued on
July 31, applied only to the named plaintiffs in the suit.
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Nov 13, 2023 | 
mondaq.com | Bryan Schneider |Scott Pearson |Mehul Madia
On October 19, the Consumer Financial Protection Bureau (CFPB)
issued its highly anticipated notice of
proposed rulemaking to implement Section 1033 of the Dodd-Frank
Act. The Personal Financial Data Rights Rule would require
depository and non-depository entities, including providers of
payment facilitation services, to make available to consumers and
authorized third parties certain data relating to the
consumers' accounts.
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Nov 8, 2023 | 
jdsupra.com | Mehul Madia |Scott Pearson |Bryan Schneider
On October 19, the Consumer Financial Protection Bureau (CFPB) issued its highly anticipated notice of proposed rulemaking to implement Section 1033 of the Dodd-Frank Act. The Personal Financial Data Rights Rule would require depository and non-depository entities, including providers of payment facilitation services, to make available to consumers and authorized third parties certain data relating to the consumers’ accounts.
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Sep 15, 2023 | 
mondaq.com | Scott Pearson |Bryan Schneider |Mehul Madia |Eric Knight
On September 8, 2023, the U.S. District Court for the Eastern
District of Texas issued an opinion and order vacating a March 2022
anti-discrimination update to the UDAAP section of the Consumer
Financial Protection Bureau's ("CFPB" or
"Bureau") Supervision and Examination Manual ("Exam
Manual"), holding that the Bureau exceeded its statutory UDAAP
authority and that the Bureau's funding structure is
unconstitutional.
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Sep 14, 2023 | 
jdsupra.com | Mehul Madia |Scott Pearson |Bryan Schneider
September 14, 2023 Mehul Madia, Scott Pearson, Bryan Schneider, Charles Washburn, Jr. Manatt, Phelps & Phillips, LLP + Follow x Following x Following - Unfollow Contact To embed, copy and paste the code into your website or blog: The Consumer Financial Protection Bureau’s (CFPB or Bureau) Summer 2023 Supervisory Highlights, which discusses key examination findings between July 2022 and March 2023, underscores the Bureau’s continuing aggressive interpretations of its authority. In addition to...
