Jason M. Cover focuses on federal and state consumer lending and payments laws, including those that apply to installment loans, vehicle-secured loans, lines of credit, unsecured loans, credit cards, point of sale finance and timeshare/vacation finance. He counsels providers of consumer financial services, including banks, licensed lenders and fintech providers, on regulatory compliance matters and government supervisory and enforcement matters.
Jason regularly provides guidance on electronic payments and payment network rules, electronic contracting and mobile commerce, online banking, retail installment sales, preparing for examinations by the Consumer Financial Protection Bureau (CFPB), responding to CFPB supervisory requests (including so-called PARR letters), Article 9 of the Uniform Commercial Code, lease-purchase transactions and consumer protection laws, such as the Telephone Consumer Protection Act (TCPA), Truth in Lending Act (TILA), Fair Credit Reporting Act (FCRA), Equal Credit Opportunity Act (ECOA), Electronic Funds Transfer Act (EFTA), Electronic Signatures in Global and National Commerce Act (E-SIGN), UDAAP statutes prohibiting unfair, deceptive, and abusive acts and practices and the CFPB's Rule on Payday, Vehicle Title and Certain High-Cost Installment Loans (Payday Rule).
Experience
Representative Matters
- Assisted multiple clients with drafting consumer-facing agreements, including payment authorizations and associated TILA disclosures, for installment loan, line of credit, credit card and buy now pay later programs.
- Conducted regulatory due diligence on card issuers, online-installment lenders, title lenders, timeshare/vacation sellers, small business lenders and other entities focused on consumer financial services.
- Advised fintech and marketplace lending clients in establishing online loan operations, application flow processes and bank programs.
Professional Highlights
Professional Activities
American Bar Association, Business Law Section, Consumer Financial Services Committee; Co-Vice Chair, Fair Access to Financial Services Subcommittee
Past Young Lawyer Liaison, Fair Access to Financial Services Subcommittee; past Young Lawyer Liaison, Committee Newsletter
Recognition & Accomplishments
Phi Beta Kappa, Ohio University
Golden Key International Honor Society, Ohio University
Speaking Engagements
"CFS in Turbulent Times: A Look at the Landscape for Fintech – Bank Model and Marketplace Lending Programs," Ballard Spahr webinar, December 14, 2020
"CFS in Turbulent Times: Small Dollar Lending," Ballard Spahr webinar, December 1, 2020
Speaker, "Texas Update: An Overview of the OCCC's New CAB Regulations," Short-Term Loan Bar Association, November 13, 2020
Publications
Staff Editor, Federal Regulation of Consumer Financial Services Treatise, American Bar Association
'"What's Going On? The CFPB Reassesses Its Rule Governing 'Payday, Vehicle Title, and Certain High-Cost Installment Loans,'" American Bar Association Consumer Financial Services Committee Newsletter, March 1, 2019
"OCC Updates Examiner Guidance on "Deposit-Related Credit," National Law Review, September 27, 2018
Co-author, Chapter 9, "Billing Error Resolution," The Law of Truth in Lending 2018 Supplement, American Bar Association
Credentials
Education
New York University School of Law (J.D. 2006)
Senior Notes Editor, 2005-2006; Staff Editor, 2004-2005, Journal of Law and Business
Ohio University (B.A., cum laude, 2002)
Admissions
New York
Pennsylvania
U.S. District Court for the Eastern District of New York
U.S. District Court for the Southern District of New York