On June 16, Vermont Governor Phil Scott signed H.648, a wide‑ranging financial services bill that, among other changes, brings sales‑based financing and certain factoring arrangements squarely within the state’s regulated financial services framework. The sales‑based financing provisions were added late in the process, borrowing heavily from the most controversial elements of Texas’s 2025 HB
Today, the Consumer Financial Protection Bureau (CFPB or Bureau) released its final rule revising the 2023 small business lending data collection and reporting rule under the Equal Credit Opportunity Act (ECOA) and Regulation B, which implements Section 1071 of the Dodd-Frank Act (2026 Final Rule). The 2026 Final Rule will become effective 60 days after
In two recent litigation status reports, the Consumer Financial Protection Bureau (CFPB or Bureau) indicated that it is working to issue interim final rules for both Section 1071 and Section 1033 in light of an opinion from the U.S. Department of Justice’s Office of Legal Counsel (OLC) concluding that the Bureau cannot lawfully draw funds
The Consumer Financial Protection Bureau (CFPB or Bureau) has issued a new proposed rule that would substantially revise the 2023 small business lending data collection and reporting rule under the Equal Credit Opportunity Act (ECOA) and Regulation B, which implements Section 1071 of the Dodd-Frank Act. The proposal re-centers Section 1071 on “core” providers, products,
On November 10, the Tenth Circuit reversed the district court’s preliminary injunction in the challenge to Colorado’s H.B. 23‑1229, holding that Colorado may enforce its Uniform Consumer Credit Code (UCCC) interest‑rate caps for loans to Colorado borrowers even when originated by out‑of‑state, state‑chartered banks. Interpreting the Depository Institutions Deregulation and Monetary Control Act (DIDMCA) §
On October 2, the Consumer Financial Protection Bureau (CFPB or Bureau) published a final rule in the Federal Register, officially extending compliance dates for its 2023 small business lending data collection and reporting rule under the Equal Credit Opportunity Act (ECOA) and Regulation B, which implements Section 1071 of the Dodd-Frank Act. The final rule
In the last two weeks, several amicus briefs were filed in the Tenth Circuit in the ongoing litigation concerning Colorado’s opt-out from the Depository Institutions Deregulation and Monetary Control Act (DIDMCA). Troutman Pepper submitted a brief on behalf of all 50 state bankers associations (state bankers), plus Washington, D.C., supporting the district court’s granting of
Please join Troutman Pepper Partner Chris Willis and his colleagues Mark Furletti, Joe Reilly, and Christine Emello for the last installment of a special three-part series about the Consumer Financial Protection Bureau’s (CFPB) new small business lending data collection and reporting final rule — the Section 1071 rule. Part 3 focuses on specific areas, including
Please join Troutman Pepper Partner Chris Willis and his colleagues Lori Sommerfield and Caleb Rosenberg for the second installment of a special three-part series about the Consumer Financial Protection Bureau’s (CFPB) new small business lending data collection and reporting final rule — the Section 1071 rule. Part 2 takes a deeper dive into the rule’s
Please join Troutman Pepper Partner Chris Willis and his colleagues Lori Sommerfield, Addison Morgan, and Josh McBeain for the first installment of a special three-part series about the Consumer Financial Protection Bureau’s (CFPB) new small business lending data collection and reporting final rule — the Section 1071 rule. Part 1 of this special series provides