The CFPB has published its Fall 2022 rulemaking agenda as part of the Fall 2022 Unified Agenda of Federal Regulatory and Deregulatory Actions. The agenda’s preamble indicates that.
The Center for Responsible Lending (CRL) and the Consumer Bankers Association (CBA) have filed a joint petition with the CFPB that urges the Bureau to engage in rulemaking to define.
The CFPB has published its Fall 2021 rulemaking agenda as part of the Fall 2021 Unified Agenda of Federal Regulatory and Deregulatory Actions. The agenda’s preamble indicates that the.
In December 2020, after the U.S. Supreme Court ruled that the CFPB’s structure was unconstitutional and remanded the case for further consideration, a unanimous panel of the U.S. Court .
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Since the inception of the Consumer Financial Protection Bureau (CFPB or Bureau), much debate has occurred over a key threshold question: how should regulators or lawmakers decide that a novel product constitutes a “lending product”? Is the product at issue in the bailiwick of banking or insurance regulators? Not only has the question (“is it credit”?) been unfolding recently in regards to potential regulation of fintech providers and certain earned wage access products, this classification question also often arises with respect to brick-and-mortar outlets, point-of-sale transactions, or products that have otherwise been around for some time, e.g., rent-to-own or pension-advance services and structured settlements.