Consumer Financial Services

Twenty-one Democratic state attorneys general claim that many Federal Housing Administration (FHA)-approved mortgage servicers have routinely flouted the agency’s mandated COVID-19-related relief options, including its loan modification program. In a December 21 letter to the FHA , the state attorneys general asked the FHA to ensure that all FHA lenders are implementing and fully complying

Colorado and Delaware have enacted new laws for automatic renewal or negative options offers. The new laws became effective January 1, 2022. Illinois already has a law on the books related to automatic renewals but has recently made a few minor amendments to it.

Colorado. Companies must disclose the following in a clear and conspicuous

On October 20, the New York Department of Financial Services (NYDFS) published a notice in the New York State Register announcing that it has issued a proposed regulation to implement S 5470-B, which requires disclosures for commercial financing transactions of $2.5 million or less under a commercial financing agreement.

The notice allows for public

On October 18, consumer advocate groups and 19 state attorneys general wrote comment letters, urging banking regulators to denounce “rent-a-bank” arrangements between financial institutions and fintechs or other third-party providers.

The consumer advocates and attorneys general both push regulators to address and denounce financial institutions partnering with nonbanks to engage in high-cost lending otherwise prohibited

On October 5, California Governor Gavin Newsom signed SB 497, legislation that restricts the types of prepaid accounts that can be used to receive certain government assistance payments. According to the National Consumer Law Center (NCLA), an advocacy organization that sponsored the legislation, the now-enacted law will “close a loophole that allows nonbank prepaid card

On July 12, the Virginia State Corporation Commission (Commission) issued an order amending regulations for short-term lending licensees under Va. Code § 6.2-1800, et seq. (Chapter 18). This licensing regime stems from the Virginia General Assembly’s passage of the Fairness in Lending Act that took effect on January 1.

The Commission’s Bureau of Financial Institutions

While active in the space for several years, state attorneys general have taken increasingly aggressive action over the last year to regulate crypto-based products and services and prosecute those abusing this otherwise exciting innovation. In a recent article, we summarize the basics of crypto, as well as recent actions by state attorneys general involving crypto-based