Substance Over Form

The CFPB, along with the State of Maine, filed an amicus brief with the Supreme Court of Maine, dated July 12, 2023, arguing that determining whether a loan is covered by TILA requires assessing all material facts and circumstances relevant to determine the borrower’s primary purpose of entering into the transaction. In short, this case involves borrowers who took out … Read More

Junk Fees

“Junk Fees” seems to be the catchphrase of the year. In his State of the Union address on February 7, 2023, President Biden urged Congress to enact legislation eliminating junk fees. As a result, Senators Blumenthal (CT) and Whitehouse (RI) have introduced the Junk Free Prevention Act. The introduced legislation specifically targets excessive online ticket fees, airline family seating fees, … Read More

June 2023’s Regulatory Recap

June 2023’s Regulatory Recap is now available here. It includes guidance on third-party risk management, commercial real estate loan accommodations and workouts, small business lending FAQs, and others. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule … Read More