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CFPB Issues Preemption Determination that State Commercial Financing Disclosure Laws Are Not Preempted By TILA

May 5, 2023 By Aldys London and Aileen Ng

A&B Abstract: The Consumer Financial Protection Bureau (CFPB) recently announced that it issued a final preemption determination concluding that certain state disclosure laws applicable to commercial financing transactions in California, New York, Utah, and Virginia are not preempted by the federal Truth in Lending Act (TILA). As covered in a previous post, we note that […]

Filed Under: California, Consumer Financial Protection Bureau (CFPB), State Law, Truth in Lending Act (TILA) Tagged With: #California, #CFPB, #New York, #Utah, commercial financing, disclosures, preemption, TILA

New York’s Commercial Finance Disclosure Law Set to Take Effect August 1, 2023

April 4, 2023 By Stephen Ornstein and Josh Dhyani

A&B Abstract: New York is one of the first states that enacted laws requiring consumer-style disclosures for commercial financing transactions (the “New York Law”). Previously, the New York Department of Financial Services (“NYDFS”) issued guidance stating that compliance with the requirements would be delayed until it issued final implementing regulations. Those final regulations were published […]

Filed Under: State Law Tagged With: #New York, #NYDFS, commercial financing, disclosures

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Recent Posts

  • Consumer Finance State Roundup
  • CFPB Issues Preemption Determination that State Commercial Financing Disclosure Laws Are Not Preempted By TILA
  • New York’s Commercial Finance Disclosure Law Set to Take Effect August 1, 2023
  • Second Circuit Deepens Circuit Split over CFPB Funding Structure
  • States Continue Trend Supporting Remote Work for MLOs and Mortgage Company Employees
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