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CFPB Proposes Nonbank Registry to Focus on Compliance “Recidivism”

January 11, 2023 By Nanci Weissgold, Anoush Garakani and Melissa Malpass

A&B ABstract: On December 12, 2022, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule to require certain non-banks to register with the agency when they become subject to a public written order or judgment imposing obligations based on violations of certain consumer protection laws. The CFPB also proposes to maintain a public online […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Consumer Loan, Dodd-Frank Act, Mortgage Loans, Mortgage Servicing, Unfair, Deceptive and Abusive Acts or Practices (UDAAP) Tagged With: #CFPA, #CFPB, mortgage lending, Mortgage Servicing, Servicing

CFPB Sues MoneyLion over Membership Program, Uses Military Lending Act as Hook

October 5, 2022 By Sam Bragg and Kelley Barnaby

A&B Abstract: On September 29, 2022, the Consumer Financial Protection Bureau (“CFPB”), sued MoneyLion Technologies Inc. and 37 of its subsidiaries (“MoneyLion”) in New York federal court for violations of the Military Lending Act (the “MLA”) and Consumer Financial Protection Act (“CFPA”). The Allegations The CFPB alleges that MoneyLion offered installment loans that consumers could […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Consumer Loan, Dodd-Frank Act Tagged With: #CFPA, #CFPB, #New York

California Settlement Offers Reminder that Buy Now Pay Later Participants are Subject to California Financing Law

September 15, 2022 By Ross Speier and Josh Dhyani

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 […]

Filed Under: California, Consumer Loan, Licensing Tagged With: #BNPL, #California, fintech

NMLS Seeks Comments on Proposed Revisions to Company and Individual Disclosure Questions

August 10, 2022 By Nanci Weissgold, Anoush Garakani and Aileen Ng

A&B Abstract: The Nationwide Multistate Licensing System & Registry (NMLS) Policy Committee is inviting comments on the NMLS Disclosure Questions Proposal. The comment period is now open and runs until August 22. Among other revisions, the proposal details suggested revisions to the disclosure questions on the Company (MU1) and Individual (MU2) forms. Proposed Revisions to […]

Filed Under: Consumer Loan, Licensing, State Law Tagged With: CSBS, licensing, NMLS

Rhode Island Expands Lender Licensing for Retail Installment Contracts, Allows Remote MLO Work, and Makes Other Changes to Financial Institutions Laws

August 9, 2022 By Josh Dhyani

Rhode Island made a number of amendments to financial institutions statutes with the passage of Senate Bill 2794 / House Bill 7781 Sub A. Changes include the scope of licensing requirements applicable to retail installment contracts and the permissibility of remote work for MLOs and other employees. The changes were effective upon passage on June […]

Filed Under: Consumer Loan, Licensing, Mortgage Loans, State Law Tagged With: Mortgage, Rhode Island

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Recent Posts

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