A&B Abstract: On May 4, 2023, Governor Holcomb signed SEA 458, the Model Money Transmission Modernization Act (the “MTMA”), into law in Indiana. The MTMA repeals and replaces Indiana’s existing law on money transmitters and, in doing so, … [Continue reading] about New Indiana Money Transmission License Requirements Impact Business Purpose Activities
Don’t Miss the Small Stuff Lenders: New Mexico Issues Regulatory Guidance for Completing the “Freedom to Choose” Insurance Company Form
A&B Abstract: Under New Mexico’s Insurance Code, it has been a long-standing requirement that lenders may not condition a loan of money on the procurement of insurance from any particular insurer, agent, solicitor, or broker. The lender is … [Continue reading] about Don’t Miss the Small Stuff Lenders: New Mexico Issues Regulatory Guidance for Completing the “Freedom to Choose” Insurance Company Form
CFPB Amicus Brief in FDCPA Case Signals Its Stance on Liability for False Statements
A&B Abstract: On January 2, the Consumer Finance Protection Bureau (“CFPB” or “Bureau”) filed an amicus brief in Carrasquillo v. CICA Collection Agency, Inc. in support of Plaintiff-Appellant Carrasquillo. The brief challenges the District … [Continue reading] about CFPB Amicus Brief in FDCPA Case Signals Its Stance on Liability for False Statements
Mortgage Servicers: VA Issues Guidance Regarding Noncompliance in Processing VA Assumptions
A&B Abstract: On December 20, 2023, the Department of Veterans Affairs (VA) issued Circular 26-23-27 (the “Circular”) to remind holders and servicers of VA-guaranteed loans about their obligation to process assumptions and how the VA will … [Continue reading] about Mortgage Servicers: VA Issues Guidance Regarding Noncompliance in Processing VA Assumptions
OCC Issues Guidance on “Buy Now, Pay Later” Lending
A&B Abstract: On December 6, 2023, the Office of the Comptroller of the Currency (OCC) issued a bulletin aimed at providing guidance to national banks and federal savings associations (“Financial Institutions”) involved in "buy now, pay later" … [Continue reading] about OCC Issues Guidance on “Buy Now, Pay Later” Lending