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January

22
2024
Industry News

Maryland is Latest State to Introduce Legislation Targeting Bank Partnership Programs

On January 10, HB 254, entitled the True Lender Act, was introduced before the Maryland House of Delegates. The Act would amend the Maryland Commercial Law to add an article containing both predominant economic interest and totality of the circumstance tests to determine the “true lender” of a loan.

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January

22
2024
Trends

Average Car Payment and Auto Loan Statistics 2024

The average car payment for new vehicles was $726 in the third quarter of 2023, a 3.6% increase from the third quarter of 2022. The average car payment for leased vehicles increased at a comparable 4.6%. However, the average car payment for used vehicles increased by just 0.8%.

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January

22
2024
Industry News

CFPB Files Amicus Brief in FDCPA Appeal

This month, the Consumer Financial Protection Bureau (CFPB) started the new year by filing an amicus brief in an ongoing appeal in the First Circuit focusing on an interpretation of the Fair Debt Collection Practices Act (FDCPA), specifically 1692e.

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January

19
2024
Compliance

How “location, location, location” can lead to “enforcement, enforcement, enforcement”

Do consumers attend a Christian church? Are they the parents of preschoolers? Would the description “wealthy and not healthy” apply to them? By tracking people’s mobile devices, Texas-based InMarket Media has collected their precise geolocation and cross-referenced their location histories with other personal data to categorize them into roughly 2,000 different audience segments that the company then marketed for the purpose of targeted advertising. According to a proposed FTC complaint,

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January

19
2024
Industry News

CFPB Proposes Rule on Overdraft Fees for Public Comment

The proposal would amend Regulations E and Z and includes a benchmark for overdraft fees compared to bank costs. Comments are due by April 1.

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