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CFPB Announces Annual Threshold Adjustments for Credit Cards and Mortgages

Troutman Sanders

Specifically, the final rule provides for the following adjustments: For open-end consumer credit plans under TILA, the threshold that triggers requirements to disclose minimum interest charges will remain unchanged at $1.00 The rule takes effect on January 1, 2024.

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Updates to TILA Interagency Guidance and Certain Annual Thresholds

Troutman Sanders

Two important updates impacting compliance with the Truth in Lending Act (TILA) and Reg Z have just been announced. The TILA Examination Procedures have been revised and updated to reflect four final rules that amend the qualified mortgage (QM) provisions of Regulation Z. For QMs under the General QM loan definition in Section 1026.43(e)(2),

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

The debt relief is broken down into the following categories: $1.7 Under the proposal, an institution subject to the rule would have to provide full TILA disclosures and comply with other substantive TILA requirements for overdraft fees if they exceed costs or a low CFPB safe harbor amount.

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FTC Fines Vonage $100M for “Junk Fees” and Using “Dark Patterns” to Make It Hard for Consumers to Cancel

Troutman Sanders

The report highlighted multiple enforcement actions under each of four different FTC-identified dark pattern categories and concluded with the stern warning that “[f]irms that nonetheless employ dark patterns, take notice: where these practices violate the FTC Act, ROSCA, the TSR, TILA, CAN-SPAM, COPPA, ECOA, or other statutes and regulations enforced (..)

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Troutman Pepper Weekly Consumer Financial Services Newsletter

Troutman Sanders

Specifically, FinCEn is issuing a final rule, requiring certain entities to file with FinCEN reports that identify two categories of individuals: the beneficial owners of the entity and individuals who have filed an application with specified governmental authorities to create the entity or register it to do business.

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Credit Acceptance and National Trade Associations Challenge the CFPB and NY AG’s Attempt to Disregard TILA and Regulate the Indirect Auto Finance Industry Through Litigation

Troutman Sanders

3) Assignees of consumer credit contracts are only liable under the Truth in Lending Act for violations that are apparent on the face of the TILA disclosure statement and other assigned documents, whereas alleged hidden finance charges, by definition, cannot meet this test.

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