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2 days ago | 
jdsupra.com | Jason Cover |Joseph Reilly |Caleb Rosenberg
On June 20, the Texas Legislature passed H.B. 700, which introduces several new regulatory requirements for providers and brokers of commercial sales-based financing operating within the state. The law applies to merchant cash advance transactions and loans with payments that vary based on the borrower’s sales.
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4 weeks ago | 
jdsupra.com | Jason Cover |Mark J. Furletti |Chris Willis
New York has included a “Buy-Now-Pay-Later Act” as part of its broader budget legislation for the 2025-2026 fiscal year. Encapsulated in Article 14-B, the Act aims to regulate the burgeoning market of buy-now-pay-later (BNPL) lenders but has raised concerns by its overreach and seemingly unequal treatment of national and state banks.
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1 month ago | 
openlegalblogarchive.org | Jason Cover |Mark J. Furletti |Chris Willis
New York has included a “Buy-Now-Pay-Later Act” as part of its broader budget legislation for the 2025-2026 fiscal year. Encapsulated in Article 14-B, the Act aims to regulate the burgeoning market of buy-now-pay-later (BNPL) lenders but has raised concerns by its overreach and seemingly unequal treatment of national and state banks.
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1 month ago | 
openlegalblogarchive.org | Jason Cover |Carlin McCrory
In this episode of Payments Pros, Carlin McCrory introduces Jason Cover as a new co-host. Jason, a partner in Troutman Pepper Locke’s Consumer Financial Services practice, brings extensive knowledge in consumer lending and payments laws. He advises clients on electronic payments, online small business lending, electronic consents, contracts, disclosures, and recurring payment methods.
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1 month ago | 
insidearm.com | Jason Cover
On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This proposal marks a significant shift in the Bureau’s approach to supervising nonbank entities. Public comments on the rescission will be accepted until June 13, 2025.
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1 month ago | 
jdsupra.com | Jason Cover |Mark J. Furletti |Stefanie Jackman
On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This proposal marks a significant shift in the Bureau’s approach to supervising nonbank entities. Public comments on the rescission will be accepted until June 13, 2025.
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1 month ago | 
openlegalblogarchive.org | Jason Cover |Mark J. Furletti |Stefanie Jackman |Jesse Silverman
On May 14, the Consumer Financial Protection Bureau (CFPB or Bureau) published a proposed rule to rescind amendments to its Procedures for Supervisory Designation Proceedings, originally adopted in 2022 and 2024. This proposal marks a significant shift in the Bureau’s approach to supervising nonbank entities. Public comments on the rescission will be accepted until June 13, 2025.
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1 month ago | 
jdsupra.com | Jason Cover |Stefanie Jackman |Jesse Silverman
Yesterday, the Consumer Financial Protection Bureau (CFPB or Bureau) released a proposed rule to rescind its previous regulation requiring nonbank entities to report certain agency and court orders to a Bureau registry. The rule, initially adopted on July 8, 2024, mandated nonbank covered persons to disclose final public orders related to consumer financial products or services.
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1 month ago | 
jdsupra.com | Jason Cover |Mark J. Furletti |Ethan G. Ostroff
The Consumer Financial Protection Bureau (CFPB or Bureau) announced a significant shift in its enforcement priorities, choosing not to prioritize actions related to Buy Now, Pay Later (BNPL) loans under the Truth in Lending (Regulation Z). This decision aligns with the CFPB’s broader strategic adjustments outlined last month, and discussed here, which emphasize focusing resources on more pressing consumer threats, particularly those affecting servicemen, veterans, and small businesses.
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2 months ago | 
openlegalblogarchive.org | Jason Cover |Mark J. Furletti |Joseph Reilly |Caleb Rosenberg
Last month, the Texas legislature introduced two companion bills, S.B. No. 2677 and H.B. No. 700, to regulate sales-based commercial financing. For purposes of the proposed legislation, sales-based financing is a transaction that is repaid as a percentage of sales or revenue, or according to a fixed payment mechanism that provides for a reconciliation process to adjust payments to an amount that is a percentage of sales or revenue.
