A&B Abstract: Effective January 1, 2020, Rhode Island will regulate virtual currency under its money transmission laws. Background Forty-nine states and the District of Columbia regulate money transmission. Almost all of those jurisdictions … [Continue reading] about Rhode Island Requires Licensure for Virtual Currency Business Activity
QM Patch Update: CFPB Proposes to Let Patch Expire
A&B Abstract The CFPB has issued an Advance Notice of Proposed Rulemaking regarding the fate of the “QM Patch,” indicating that it will not extend the “QM Patch” permanently. Advanced Notice of Proposed Rulemaking In a surprise development, on … [Continue reading] about QM Patch Update: CFPB Proposes to Let Patch Expire
A Closer Look at the CFPB’s Proposed Debt Collection Rules – Part One
A&B Abstract: On May 7, 2019, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) issued a proposed rule that would significantly amend Regulation F (the “Proposed Rule”), which implements the Fair Debt Collection Practices Act … [Continue reading] about A Closer Look at the CFPB’s Proposed Debt Collection Rules – Part One
Student Loan Servicers Remain Liable Under State Law for Affirmative Misrepresentations to Borrowers
A&B Abstract: The Seventh Circuit recently held that the federal Higher Education Act does not preempt state law consumer protection and tort claims where student loan servicers made affirmative misrepresentations to borrowers regarding … [Continue reading] about Student Loan Servicers Remain Liable Under State Law for Affirmative Misrepresentations to Borrowers
Maryland Clarifies New Net Worth Requirements for Mortgage Servicers
A&B Abstract: Effective October 1, 2019, the Maryland Commissioner of Financial Regulation will impose new net worth requirements on licensees. Importantly, Maryland servicing licensees without GSE approvals may not use a line of credit to … [Continue reading] about Maryland Clarifies New Net Worth Requirements for Mortgage Servicers