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Category Archives: CFPB General

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CFPB soliciting suggestions for its amicus brief program

Posted in CFPB General

The Consumer Law & Policy Blog has reproduced a copy of a letter sent yesterday by the CFPB seeking suggested cases for the CFPB’s amicus brief program.  The letter indicates that the amicus program has so far filed 14 amicus briefs in the federal courts of appeals and has worked closely with the Solicitor General’s Office… More >

Banking trade groups comment on CFPB’s proposed no-action letter policy

Posted in CFPB General, Technology

The American Bankers Association, American Bankers Insurance Association and Consumers Banking Association have submitted a joint comment letter on the CFPB’s proposed policy on issuing “no-action” letters for innovative financial products or services. The trade groups expressed the overall concern that the proposal will not “serve as a viable approach to alleviating regulatory uncertainty” because… More >

CFPB’s proposed boarding form for online consumer complaint company portal now available

Posted in CFPB General

Last week, the CFPB published a Federal Register notice stating that it was developing a form to allow companies to “proactively participate” in its online company portal for viewing and responding to consumer complaints.  Although the CFPB’s proposed form, the “Company Portal Boarding Form,” was not available when the notice was published, the proposed form… More >

CFPB issues sixth Semi-Annual Report

Posted in CFPB General

The CFPB has issued its sixth Semi-Annual Report to the President and Congress covering the period from April 1 through September 30, 2014. As we have found with previous CFPB semi-annual reports, despite its 188-page length, the latest report provides no noteworthy new information about CFPB activities.  Instead it recycles information in various previously-issued CFPB reports and… More >

CBO issues cost estimate for Bureau Advisory Opinion Act

Posted in CFPB General

The Congressional Budget Office (CBO) recently released a cost estimate for H.R. 4662, entitled the “Bureau Advisory Opinion Act.”  This was part of series of bills reported in June 2014 by the House Committee on Financial Services that were intended to promote greater transparency and accountability at the CFPB. H.R. 4662 would require the CFPB to establish procedures… More >

High Praise from Above the Law

Posted in CFPB General

“There’s blogging, and then there’s blogging well. And really, an argument can be made that anything but the latter really isn’t blogging at all.” So begins Above the Law’s commentary on Law Blogs and I’m happy to report that our CFPB Monitor fared exceptionally well. We started the blog in 2011 to coincide with the… More >

CFPB creating boarding form for online consumer complaint company portal

Posted in CFPB General

The CFPB has published a notice in today’s Federal Register stating that the CFPB is developing a form to allow companies to “proactively participate” in its online company portal for viewing and responding to consumer complaints. According to the notice, the CFPB’s proposed form, the “Company Portal Boarding Form,” will “serve to streamline information collection” from… More >

CFPB’s Ombudsman’s Office issues third annual report

Posted in CFPB General

Last week, the CFPB’s Ombudsman’s Office issued its third annual report covering the Office’s activities during fiscal year 2014 (October 1, 2013 through September 30, 2014).  The role of the Ombudsman’s Office is to assist in the resolution of individual and systemic issues that a depository entity, non-depository entity or consumer has with the CFPB. A… More >

CFPB to host research conference on consumer finance

Posted in CFPB General

The CFPB has announced that it plans to host its first “Research on Consumer Finance” conference in Washington, D.C. on May 7-8, 2015. The announcement includes a call for research papers to be submitted by January 16, 2015.  The CFPB seeks complete papers or detailed abstracts that include preliminary results dealing with “the ways consumers… More >

CFPB Proposes Additional Servicing Rule Amendments

Posted in CFPB General, CFPB Rulemaking, Mortgages, TILA / RESPA

The CFPB issued a proposed rulemaking last week to amend various provisions of the mortgage servicing rules under Regulation X and Regulation Z. Comments are due 90 days from the date of publication in the Federal Register. Ballard Spahr’s Mortgage Banking Group will continue to analyze the proposal and work with our clients and industry… More >

CFPB Director Cordray Issues Warning to Bankers

Posted in CFPB General, Richard Cordray

Director Cordray’s remarks to the Clearing House yesterday should unsettle bankers and payday lenders alike. In his talk, Director Cordray challenged bankers to bow to the inevitable. He suggested that sooner, rather than later, the industry should invest the billions of dollars required to build a payment system with “faster and even real-time payments” where… More >

CFPB gives guidance and answers FAQ on the new Closing Disclosure

Posted in CFPB General, CFPB Rulemaking, TILA / RESPA

On November 18, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar that addressed questions about the Final TILA-RESPA Integrated Disclosure Rule that will be effective for applications received by creditors or mortgage brokers on or after August 1, 2015.  The webinar focused on the Closing Disclosure and addressed specific questions regarding the… More >

OIG updated work plan includes evaluations of CFPB enforcement-related processes and procedures

Posted in CFPB General

The Office of Inspector General’s (OIG) work plan, updated as of November 7, 2014, indicates that the OIG’s ongoing projects include audits of the CFPB’s information security program, pay and compensation program, distribution of civil penalty funds, public consumer complaint database and headquarters renovation costs.  Such projects also include an evaluation of the CFPB’s hiring… More >

CFPB’s constitutionality again before D.C. Circuit in Morgan Drexen appeal

Posted in CFPB General

The CFPB’s constitutionality is again before the D.C. Circuit, with the D.C Circuit now being asked to consider the impact of the U.S. Supreme Court’s decision in NLRB v. Canning on actions taken by the CFPB while Director Cordray was serving as a recess appointee.  In that decision, the Supreme Court ruled that President Obama exceeded his… More >

OIG identifies five major CFPB management challenges

Posted in CFPB General

The joint Federal Reserve/CFPB Office of the Inspector General (OIG) recently issued its first listing of “major management challenges” facing the CFPB.  These challenges represent what the OIG believes to be “the areas that, if not addressed, are most likely to hamper the CFPB’s accomplishment of its strategic objectives.”  To identify the challenges, the OIG used audit… More >

CFPB Student Loan Ombudsman Files Third Annual Report Highlighting Bureau’s Hot Button Issues in Student Lending

Posted in CFPB Enforcement, CFPB Exams, CFPB General, Student Loans

The CFPB released its third Annual Report of the Student Loan Ombudsman, Rohit Chopra, discussing complaints received by the CFPB about private student loans and the lessons drawn by the Ombudsman from those complaints.  Before turning to the substance of those complaints, and the conclusions drawn by the Ombudsman, we think it important to put… More >

CFPB Proposes No-Action Letter Policy for Innovators

Posted in CFPB General, Technology

The CFPB published for comment in today’s Federal Register a proposed policy on issuing “no-action” letters for innovative financial products or services.  Like those issued by the SEC and CFTC, the no-action letters would communicate that, subject to specific facts and circumstances, CFPB staff has no present intention to recommend initiation of an enforcement or supervisory… More >

CFPB Continues Focus on Latino Community

Posted in CFPB General, Credit Reports, Debt Collection, Diversity and Inclusion, FTC, Uncategorized

The CFPB and the FTC have announced that the agencies will host a joint roundtable entitled, “Debt Collection and the Latino Community,” on October 23, 2014. The roundtable will examine how debt collection and credit reporting issues affect Latino consumers, especially those who have limited English proficiency (LEP). Consumer advocates, industry representatives, state and federal… More >

CFPB Updates Mortgage Rules Readiness Guide to Cover TILA-RESPA Integrated Mortgage Disclosure Rule

Posted in CFPB General

The CFPB has released Version 3.0 of its “2014 CFPB Dodd-Frank Mortgage Rules Readiness Guide.”  The Guide, originally issued in July 2013, now contains changes to the final rules issued through August 1, 2014.  The updated Guide includes the TILA-RESPA Integrated Mortgage Disclosures Rule that takes effect in August 2015. According to the CFPB, the… More >

FDIC to Host Teleconference on ATR/QM and Loan Originator Compensation Final Rules

Posted in CFPB General, CFPB Rulemaking

On October 22 from 2:00 to 3:30 p.m., the FDIC’s Division of Depositor and Consumer Protection will host a teleconference as part of its periodic series of events for bankers on important banking regulatory issues in the compliance and consumer protection area.  According to the announcement, the upcoming teleconference will focus on common questions and… More >