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Jeremy focuses his practice on federal and state lending and consumer practices laws, with emphasis on the interplay between federal and state laws, joint ventures between banks and nonbank financial services providers, the development and documentation of new financial services products (especially products designed to serve the needs of unbanked and under-banked consumers), bank overdraft practices and disclosures, geographic expansion initiatives, and compliance with federal and state consumer protection laws, including statutes prohibiting unfair, deceptive and abusive acts and practices (UDAAP); usury laws; the Truth in Lending Act (TILA); the Electronic Funds Transfer Act; E-SIGN; the Equal Credit Opportunity Act; and the Fair Credit Reporting Act (FCRA).

The Federal Trade Commission (FTC) announced that it is launching an inquiry into the small business credit reporting industry. Specifically, it is ordering five firms to provide detailed information about their products and processes.

According to the FTC, the impetus for this inquiry is that unlike consumer reports, which are governed by the Fair Credit

Last year, Missouri State Senator Justin Brown (R) introduced a bill that would have imposed certain mandatory disclosure requirements for commercial financing transactions. Ultimately, the bill failed to advance. On December 1, 2022, Senator Brown reintroduced a similar bill, known as SB 187, which also requires registration of a commercial financing broker. The bill

On February 16, Illinois State Representative Hoan Huynh (D) introduced HB3064, the Small Business Truth in Lending Act, that would impose certain mandatory disclosure requirements for commercial financing transactions and require registration of small business finance companies and brokers. Illinois follows the lead of states such as New York, California, Utah, and Virginia which

This morning the U.S. Supreme Court granted the Consumer Financial Protection Bureau’s (CFPB or Bureau) petition for certiorari in Community Financial Services Association of America Ltd. (CFSA) v. CFPB, a case that could decide once and for all whether the funding mechanism for the Bureau is constitutional. The order list does not specify which

On February 1, the Superintendent of Financial Services Adrienne A. Harris announced that the New York State Department of Financial Services completed the process for adopting a new regulation relating to disclosure requirements for commercial financing. The regulation, 23 NYCRR 600, applies to multiple types of commercial financing products and requires providers to issue

As discussed here, on October 19, 2022 the Fifth Circuit Court of Appeals in Community Financial Services Association of America Ltd. (CFSA) v. Consumer Financial Protection Bureau (CFPB) held that the CFPB’s funding mechanism violates the Appropriations Clause of the U.S. Constitution. The Fifth Circuit based its decision on the fact that, among other

Please join Consumer Financial Services Partner Chris Willis and his colleagues Jeremy Rosenblum and Tony Kaye as they discuss the phenomenon of mass arbitrations, which pose increasing risk to the consumer finance industry. The partners use their knowledge to explain what mass arbitration is and describe prophylactic measures companies should take.

As discussed here, on November 18, the Biden administration filed an application with the U.S. Supreme Court to vacate the Eighth Circuit injunction temporarily pausing the administration’s student loan forgiveness program. In its application, the administration requested that the Court either vacate the injunction, or, in the alternative, to construe the application as a

As discussed here, last month, the Eighth Circuit granted an emergency motion by Republican officials in six states to temporarily pause the Biden administration’s student loan forgiveness program while they appeal the dismissal of their challenge by a Missouri federal judge, who found that they do not have standing to sue. On November 18

As discussed here, on October 19, a three-judge panel of the Fifth Circuit Court of Appeals held that the Consumer Financial Protection Bureau’s (CFPB) funding mechanism violates the appropriations clause because the CFPB does not receive its funding from annual congressional appropriations like most executive agencies, but instead receives funding directly from the Federal