On August 15, 2022, the California governor signed SB 633 into law, expanding the obligations of creditors obtaining the signatures of more than one person on a consumer credit contract, including a motor vehicle lease, who do not receive any of the money, property, or services that are subject to the consumer credit contract.… Continue Reading
CFPB and federal banking agencies issue guidance on unfair or deceptive credit practices in light of Reg AA repeal
By Barbara S. Mishkin on
Posted in Regulatory and Enforcement, UDAAP
Concurrently with a proposal from the Fed to repeal Regulation AA (12 CFR part 227), the CFPB and the federal banking agencies (Fed, OCC, FDIC and NCUA) have issued interagency guidance regarding unfair or deceptive credit practices.
The Fed adopted Reg AA in 1985 pursuant to a directive in Section 18(f)(1) of the FTC Act requiring the Fed to issue rules applicable to banks that were substantially similar to rules issued by the FTC to prohibit unfair or deceptive acts or practices by nonbanks. … Continue Reading