On Oct. 16, 2024, the Federal Trade Commission announced its final “Click-to-Cancel” Rule for subscription services and other negative option offers. The rule requires sellers to make it as easy for consumers to cancel subscriptions as it was to sign up for them. The rule also changes businesses’ marketing, disclosure, consent, and recordkeeping requirements and

On Oct. 2, 2024, the Federal Deposit Insurance Corporation (FDIC) published a notice of proposed rulemaking (Proposed Rule) designed to strengthen recordkeeping requirements for custodial deposit accounts with transactional features, like those often used in banking-as-a-service (BaaS) models and other bank-fintech partnerships. The Proposed Rule is intended to ensure the FDIC’s ability to promptly make

On June 4, 2024, the CFPB released a circular cautioning companies against including unlawful or unenforceable terms and conditions in contracts for consumer financial products or services. The circular asserts that companies often embed unlawful or unenforceable terms in the fine print of their contracts, using this “fine print tactic” to deceive consumers into surrendering

On May 30, 2024, the CFPB issued a new request for information (RFI) from the public regarding “why closing costs are increasing, who is benefiting, and how costs for borrowers and lenders could be lowered.”

As part of a wider effort targeting what both the CFPB and the Biden administration refer to as “junk fees,”

On May 8, 2024, the California Attorney General released a list of frequently asked questions (FAQs) to help businesses comply with SB 478, California’s soon-to-be effective “Hidden Fees Statute,” a law intended to address so-called “junk fees” by prohibiting “drip pricing.”

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New York is now poised to impose Truth-in-Lending-like disclosure obligations on various types of commercial financing. On Feb. 1, the New York Department of Financial Services adopted final regulations implementing S.B. 5470 and S.B. 898.

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After years of rulemaking efforts, the Consumer Financial Protection Bureau (CFPB) may issue a final rule later this month that would require lenders to collect and report data on small business loan applications, including applications from minority-owned and women-owned small businesses. According to the CFPB, when it is implemented, the rule will create the first