April 26, 2024

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CFPB Credit history Stance Has Broad Specialty Finance Implications

Legislation360 (December 11, 2020, 5:57 PM EST) — The Shopper Economical Defense Bureau issued an advisory opinion[1] at the conclude of November that could compel specialty-finance firms — such as those supplying earnings-share agreements, litigation funding, merchant dollars developments and gained wage obtain items — to get a contemporary glance at whether or not their products are in reality matter to sure federal customer protection legislation.

While the CFPB’s Nov. 30 feeling is designed only to clarify which attained wage entry plans fall exterior Regulation Z’s definition of “credit,” it also additional commonly establishes an analytical framework likely relevant to a host of alternative monetary solutions — products that federal and condition…

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