Connecticut and Kansas recently joined California, New York, Florida, Utah, Virginia, and Georgia in enacting laws requiring lenders to provide consumer-like financing disclosures for certain
Continue Reading New Commercial Financing Laws Take Effect in Connecticut, KansasRinaldo Martinez
With a client base that spans institutional investors, private equity funds, banking institutions, mortgage lenders and servicers, consumer finance companies, fintech firms, and financial services companies, Rinaldo Martinez focuses his practice on addressing the regulatory landscape of consumer credit products, both at the federal state levels. His work necessitates delving into federal and state laws that substantively govern all aspects of consumer credit. Rinaldo also counsels on regulatory compliance issues related to commercial real estate.
As part of his practice, Rinaldo regularly navigates the complexities of Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including advising on statutes such as the Truth in Lending Act (TILA), the Real Estate Settlement Procedures Act (RESPA), the Home Mortgage Disclosure Act (HMDA), the Fair Debt Collection Practices Act (FDCPA), and the Fair Credit Reporting Act.
At the state level, his practice covers licensing statutes, anti-predatory lending laws, qualification statutes, usury limitations, and prepayment penalty restrictions. He has deep experience advising on regulatory compliance issues involving hybrid residential-commercial real property, such as “fix-flip” properties, particularly regarding licensing obligations for this product.
Rinaldo also assists clients with developing business models in the context of regulatory compliance issues arising under state law, with a focus on bank partnerships. He also assists clients with state examinations, including negotiating findings with regulators before examination report finalization. Additionally, Rinaldo assists with secondary market transactions, including securitizations, that necessitate diligence of state licensing obligations.
CFPB Proposes Interpretive Rule for Earned Wage Access Products
On July 18, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Interpretive Rule and Request for Comment (Proposed Rule) addressing credit products in the paycheck advance marketplace, such…
Continue Reading CFPB Proposes Interpretive Rule for Earned Wage Access ProductsCFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance Reports
On May 22, 2024, the Consumer Financial Protection Bureau (CFPB) issued a Final Rule (the Rule) requiring certain nonbank “covered persons” to report certain final public orders issued by a…
Continue Reading CFPB Issues Final Rule Requiring Certain Nonbanks to Report Final Public Orders and Submit Annual Compliance ReportsCFPB Unveils Final Rule Banning ‘Excessive’ Credit Card Late Fees
On March 5, 2024, the Consumer Financial Protection Bureau (CFPB) finalized a rule intended to limit late payment fees on credit cards issued by the largest credit card issuers. The…
Continue Reading CFPB Unveils Final Rule Banning ‘Excessive’ Credit Card Late Fees