truth in lending

The CFPB Sticks to Its Guns, Finding State Commercial Finance Disclosure Laws Not Preempted in Final Determination

By Krista Cooley, Francis L. Doorley, Steven M. Kaplan, Eric T. Mitzenmacher, Jeffrey P. Taft & Daniel Pearson on April 6, 2023

Posted in Commercial Financing, Consumer Financial Protection Bureau (CFPB), Preemption, Truth in Lending Act/Regulation Z

The US Consumer Financial Protection Bureau has finalized its December 2022 preliminary determination that commercial finance disclosure laws recently enacted in California, New York, Utah and Virginia are not preempted by the federal Truth in Lending Act. The CFPB’s final determination confirms for a wide range of small business financers and brokers that they are…

CFPB Preliminarily Determines State Commercial Financing Disclosure Laws Not Preempted by Truth in Lending Act

By Krista Cooley, Francis L. Doorley, Steven M. Kaplan, Eric T. Mitzenmacher, Daniel Pearson & Jeffrey P. Taft on January 6, 2023

Posted in Commercial Financing, Consumer Financial Protection Bureau (CFPB), Preemption, Rulemaking, Truth in Lending Act/Regulation Z

Small business lenders hoping for federal intervention will be disappointed to learn that the Consumer Financial Protection Bureau (CFPB) has reached a preliminary determination that New York’s new commercial financing disclosure law is not preempted by the federal Truth in Lending Act (TILA). The CFPB’s public notice indicates that it initially takes the same view…