Michael Guerrero

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Articles

Treasury Issues RFI on Use of AI in Financial Services

Jun 27, 2024 | ballardspahr.com | Michael Guerrero |Peter Hardy |Kaley Schafer |Nathaniel Botwinick

Summary After several years of monitoring and reporting on artificial intelligence (AI) in financial services, the U.S. Department of Treasury (Treasury) has embarked on initial rulemaking efforts and issued a request for information (RFI). Treasury is seeking comments from a broad array of financial services stakeholders on their use of AI, as well as the risks and opportunities the technology poses.
CFPB Takes Action Against BloomTech, Inc. for ISAs that Violate TILA, UDAAP, and the FTC’s Holder Rule

Apr 26, 2024 | consumerfinancemonitor.com | John Culhane |Michael Guerrero |Kaley Schafer |Brian Turetsky

On April 17th, the CFPB issued a consent order to a for-profit training school alleging numerous violations of law related to its use if income share agreements (“ISAs”). According to the Bureau, BloomTech, Inc. (“BloomTech”) and the company’s founder and CEO engaged in deceptive and abusive acts or practices, violated the Truth in Lending Act (“TILA”) and Regulation Z, and violated the Federal Trade Commission’s (“FTC”) Holder Rule.
Plaintiffs in credit card late fee rule case ask Fifth Circuit to keep appeal even though the district court has scheduled a preliminary injunction hearing | Ballard Spahr LLP - JDSupra

Mar 28, 2024 | jdsupra.com | John Culhane Jr. |Michael Guerrero |Alan Kaplinsky

On March 26, 2024, the plaintiffs in the lawsuit challenging the CFPB’s final credit card late fee rule (“Final Rule”) filed a Notice Regarding Their Emergency Motion for Injunction Pending Appeal and Administrative Stay in the Fifth Circuit.
Plaintiffs in credit card late fee rule case ask Fifth Circuit to keep appeal even though the district court has scheduled a preliminary injunction hearing

Mar 28, 2024 | consumerfinancemonitor.com | John Culhane |Michael Guerrero |Alan Kaplinsky |Kristen Larson

On March 26, 2024, the plaintiffs in the lawsuit challenging the CFPB’s final credit card late fee rule (“Final Rule”) filed a Notice Regarding Their Emergency Motion for Injunction Pending Appeal and Administrative Stay in the Fifth Circuit.
Court denies motion for expedited consideration of plaintiff’s preliminary injunction motion in credit card late fees suit

Mar 21, 2024 | consumerfinancemonitor.com | John Culhane |Michael Guerrero |Michael Guerrero |Alan Kaplinsky |Kristen Larson |Brian Turetsky | +1 more

On March 20, 2024, the court forcefully denied the motion for expedited consideration of plaintiff’s preliminary injunction motion in the lawsuit challenging the Consumer Financial Bureau’s (“CFPB”) final credit card late fee rule.
Court denies motion for expedited consideration of plaintiff’s preliminary injunction motion in credit card late fees suit

Mar 21, 2024 | lexblog.com | John Culhane |Michael Guerrero |Alan Kaplinsky |Kristen Larson

On March 20, 2024, the court forcefully denied the motion for expedited consideration of plaintiff’s preliminary injunction motion in the lawsuit challenging the Consumer Financial Bureau’s (“CFPB”) final credit card late fee rule.
CFPB notifies Texas federal court of intention to move to transfer case challenging final credit card late fee rule; plaintiffs seek expedited consideration of preliminary injunction motion before court decides venue issues

Mar 20, 2024 | consumerfinancemonitor.com | John Culhane |Ronald K. Vaske |Kristen Larson |Michael Guerrero

Yesterday, the CFPB filed a notice with the Texas federal district court stating that it intends to move to transfer the lawsuit challenging the CFPB’s final credit card late fee rule (Rule). The notice was filed pursuant to an order entered by the court on March 18 questioning whether the Fort Worth Division of the Northern District of Texas is the correct venue to hear the lawsuit.
Texas federal judge hearing trade group lawsuit challenging CFPB final credit card late fee rule questions whether venue is proper and orders expedited briefing

Mar 19, 2024 | consumerfinancemonitor.com | John Culhane |Ronald K. Vaske |Kristen Larson |Michael Guerrero

The federal district court judge to whom the lawsuit challenging the CFPB’s final credit card late fee rule (Rule) was reassigned entered an order yesterday questioning whether the Fort Worth Division of the Northern District of Texas is the correct venue to hear the lawsuit.
The Once and Future Rule: How the CFPB’s Credit Card Late Fee Rule Compares to Regulation Z and the Previously Proposed Rule

Mar 12, 2024 | consumerfinancemonitor.com | Alan Kaplinsky |John Culhane |Kristen Larson |Michael Guerrero

On March 5, 2024, the Consumer Financial Protection Bureau (“CFPB”) issued its final credit card late fee rule (the “Final Rule”).
Buy Now, Pay Later in an Era of Increased Scrutiny and Economic Headwinds

Feb 22, 2024 | ballardspahr.com | Michael Guerrero

Reprinted with permission from the March/April 2024 issue of ABA Risk and Compliance. After gaining popularity during the pandemic, Buy Now, Pay Later (BNPL) has become a ubiquitous form of credit used by millions of consumers to purchase goods and services, particularly in e-commerce transactions.

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Michael Guerrero

Articles

Treasury Issues RFI on Use of AI in Financial Services

CFPB Takes Action Against BloomTech, Inc. for ISAs that Violate TILA, UDAAP, and the FTC’s Holder Rule

Plaintiffs in credit card late fee rule case ask Fifth Circuit to keep appeal even though the district court has scheduled a preliminary injunction hearing | Ballard Spahr LLP - JDSupra

Plaintiffs in credit card late fee rule case ask Fifth Circuit to keep appeal even though the district court has scheduled a preliminary injunction hearing

Court denies motion for expedited consideration of plaintiff’s preliminary injunction motion in credit card late fees suit

Court denies motion for expedited consideration of plaintiff’s preliminary injunction motion in credit card late fees suit

CFPB notifies Texas federal court of intention to move to transfer case challenging final credit card late fee rule; plaintiffs seek expedited consideration of preliminary injunction motion before court decides venue issues

Texas federal judge hearing trade group lawsuit challenging CFPB final credit card late fee rule questions whether venue is proper and orders expedited briefing

The Once and Future Rule: How the CFPB’s Credit Card Late Fee Rule Compares to Regulation Z and the Previously Proposed Rule

Buy Now, Pay Later in an Era of Increased Scrutiny and Economic Headwinds

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