Insights

California DFPI Issues Final Rules on Commercial Financing UDAAP and Annual APR Reporting

By Katherine C. Fisher and Eric Mulligan

The California Department of Financial Protection and Innovation became the nation's first regulator with authority to police "abusive" acts and practices in commercial financing when it recently adopted final regulations to implement the California Consumer Financial Protection Law's provisions governing commercial financing. article continued

Online Chat Features and California's Two-Party Consent Rule for Recording Conversations

By Eric D. Mulligan

If you've been on the Web lately (and who hasn't?), you've probably seen a site with a chat feature. Consumers in several lawsuits have attempted to use those chat features as a basis for liability under Section 632.7 of the California Invasion of Privacy Act, which prohibits anyone from recording a call between specified devices without the consent of all parties. article continued

CFPB Bites of the Month - August 2023 - School Bells Ringing Loud and Clear, Vacation's Over, CFPB is Near

By Eric L. Johnson, Justin B. Hosie and Laura J. Bacon

In this month's article, we share some of our top "bites" for the prior month covered during the August 2023 webinar.

Bite 1: CFPB Publishes Report on Employer-Driven Debt

On July 20, 2023, the CFPB published a report on employer driven debt, based on an inquiry it started in June of 2022. article continued

Indiana Department of Financial Institutions Publishes Advisory Letter on Characterization and Disclosure of E-Lien Fees

By Erica A.N. Kramer

On June 30, 2023, the Indiana Department of Financial Institutions published Advisory Letter 2023-01, addressing the permissibility of e-lien fees not payable to the Indiana Bureau of Motor Vehicles. The publication was prompted by the implementation of a mandatory statewide electronic lien and title system. article continued