Last July, the OCC announced its decision to accept applications for special purpose national bank (SPNB) charters from fintech companies.  At that time we observed that, while not discussed in the materials released by the OCC, it appeared that a fintech company holding an SPNB charter would be required to be a member of the Federal Reserve System and be subject to oversight as a member bank. … Continue Reading

The CFPB has issued its fifth Financial Literacy Annual Report to Congress.  The report describes the CFPB’s ongoing financial literacy work, “with an emphasis on work during October 2016 through September 2017.”  It covers the CFPB’s financial literacy strategy, its financial education initiatives generally and those specifically targeted at students and young adults, servicemembers, economically vulnerable individuals, and older adults, and its research initiatives.… Continue Reading

The CFPB has released a new report, “Financial well-being in America,” and a new on-line interactive tool that allows consumers to measure their own financial well-being and access CFPB resources intended to help consumers meet financial goals.

In January 2015, the CFPB issued a report in which it created a definition of “financial well-being”:  “a state of being wherein a person can fully meet current and ongoing financial obligations, can feel secure in their financial future, and is able to make choices that allow enjoyment of life.” … Continue Reading

We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to covered members of the armed forces and their families. The text of H.R. 2697 is now available.

Titled the “Transparency in Military Lending Act of 2017,” the bill would add the following items to the list of mandatory disclosures required under the MLA:

  • A statement that the Department of Defense (“DoD”) and each service branch offers a variety of financial counseling services.
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On May 25, Congressman Dan Kildee (D-Michigan) referred a bill to the House Committee on Armed Services titled the “Transparency in Military Lending Act of 2017.” The proposed bill, H.R. 2697, would amend Title 10 of the United States Code, requiring creditors to provide active servicemembers (and their dependents) applying for loans with additional disclosures regarding the potential availability of lower-cost credit, as well as information about financial counseling services.Continue Reading

The CFPB has issued its fourth Financial Literacy Annual Report to Congress.  The report covers the CFPB’s activities to improve consumer financial literacy during the period from October 2015 through September 2016.  The report discusses the CFPB’s financial literacy strategy, its financial education initiatives (which include consumer tools and information and collaborations with community institutions and other government agencies), and its research initiatives (which include identifying effective financial education approaches).… Continue Reading

On October 5th, the CFPB published a notice announcing the CFPB Office of Financial Education’s intent to compile a list of companies offering existing customers free access to their credit score.  The CFPB’s stated intent in compiling this list is to educate consumers and help them make better informed financial decisions.  … Continue Reading

The CFPB released a report, “Tools for saving: Using prepaid accounts to set aside funds,” that presents the results of a research project involving a pilot program offering an incentive to prepaid card users to use a savings feature.

In December 2014, as part of its Project Catalyst, the CFPB’s initiative for facilitating innovation in consumer-friendly financial products and services, the CFPB announced a new research pilot program using insights from behavioral economics and an American Express pilot program to evaluate the effectiveness of certain practices to encourage prepaid card users to develop regular saving behavior.… Continue Reading

The CFPB has issued a report that describes a new “developmentally informed, skills-based model” for helping youth achieve financial capability.  Entitled “Building blocks to help youth achieve financial capability,” the report highlights key milestones from early childhood through young adulthood that support the development of adult financial capability, and makes recommendations “for delivering evidence-based, age-appropriate, and developmentally appropriate financial education policies and programs.” … Continue Reading

On September 15th, the FTC will hold a workshop to examine the testing and evaluation of disclosures that companies make to consumers about advertising claims, privacy practices, and other information.  The FTC’s workshop will explore how to test the effectiveness of these disclosures to ensure consumers notice them, understand them, and can use them in their decision-making. … Continue Reading