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District Court Ruling Clears Way for Small Dollar Rule Compliance Date in June 2022

USA - September 1 2021 Yesterday, in Community Financial Services Association of America, Ltd. v. Consumer Financial Protection Bureau, a lawsuit involving implementation…

Brian R. Epling, Christopher K. Friedman, Jennifer L. Galloway.

Illinois Caps Consumer Loans at 36% Rate, Limiting Consumers’ Access to Credit

USA - March 30 2021 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…

Michael M. Aphibal, Jennifer L. Galloway, Andrew J. Narod.

New FAQ Responses to Small Dollar Rule Address Auto and Mortgage Lending, Payment Transfers and Notices Inclusion

USA - August 20 2020 On Tuesday, August 11, 2020, the CFPB issued a second round of answers to Frequently Asked Questions related to the Small Dollar Rule. The FAQ…

Brian R. Epling, Jennifer L. Galloway.

OCC Proposes Clarification to True Lender Doctrine

USA - July 22 2020 Earlier this week, the OCC released a proposed rule designed to address the “true lender” doctrine, a legal test utilized by courts and regulators to…

Gabriella E. Alonso, Michael M. Aphibal, Christopher K. Friedman.

OCC, FDIC Issue Long-Awaited Valid-When-Made “Madden Fix”

USA - July 13 2020 Recently, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) issued final rules designed to…

Michael M. Aphibal, Christopher K. Friedman, Michael Gordon.