A&B ABstract On August 9, 2022, the Conference of State Bank Supervisors (CSBS) released two cybersecurity tools for nonbank financial services institutions to help them prepare for state cybersecurity examinations and, ultimately, improve cybersecurity maturity and protect financial institution infrastructure. These tools are designed to address key aspects of the Uniform Rating System for Information […]
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California Settlement Offers Reminder that Buy Now Pay Later Participants are Subject to California Financing Law
In August 2022, the California Department of Financial Protection and Innovation (“Department” or “DFPI”) entered into a consent order with a company offering point of sale financing products that the DFPI deemed to be buy now, pay later (“BNPL”) financing, for which a California Financing Law (“CFL”) license is required. The company is required to […]
Maryland Issues Executive Order Restricting Foreclosure Actions and Prohibiting Evictions During COVID-19 Emergency
A&B ABstract: Maryland’s Governor has issued an Executive Order providing that until the COVID-19 state of emergency is terminated: (1) foreclosure sales will only be valid if the servicer had notified the borrower of their rights to request a forbearance, and (2) residential and commercial evictions are prohibited if the tenant can show they suffered […]
FTC Seeks Comment on Proposed Changes to FCRA Rules for Motor Vehicle Dealers
A&B ABstract: The FTC is seeking public comment on proposed changes to five FCRA rules aimed at clarifying that these rules, as promulgated by the FTC, apply only to motor vehicle dealers, as equivalent rules promulgated by the CFPB will apply to other entities. The Federal Trade Commission (“FTC”) has announced it is seeking […]
New York Laws Require Forbearance for Private Mortgage Loans During COVID Emergency
A&B ABstract On June 17, 2020, New York Governor Andrew Cuomo signed into law two measures, effective immediately, providing for mortgage forbearances for privately backed residential mortgage loans during the COVID-19 emergency. Senate Bill 8243 (2020 N. Y. Laws 112) amends the N. Y. Banking Law by adding new Section 9-x, “Mortgage Forbearance.” Senate Bill […]