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Posts in Truth in Lending Act (TILA).
States Look to Impose Financing Disclosure Requirements on Commercial Loans and the CFPB Considers Potential TILA Preemption Considerations

In December 2021, the Bureau of Consumer Financial Protection (or the “CFPB”) issued a notice and request for comment (the “Notice”) on its intention to make a preemption determination regarding the Truth in Lending Act (“TILA”) and the State of New York’s Commercial Financing Law, which imposes disclosure requirements on certain commercial lending transactions (the “New York CFL”). The preemption determination had been requested by the Small Business Finance Association (the “SBFA”), a non-profit advocacy organization for its members who provide ...

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