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Category Archives: CFPB Rulemaking

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CFPB Fall 2014 rulemaking agenda indicates further delay in proposed debt collection and other rules

Posted in CFPB Rulemaking

Based on the CFPB’s Fall 2014 rulemaking agenda, proposed rules dealing with payday loans/deposit advance products, overdrafts, and debt collection are still months away. The CFPB’s timetables for “prerule activities” are February 2015 for payday loans/deposit advance products, July 2015 for overdrafts, and April 2015 for debt collection.  The CFPB’s Spring 2014 agenda had given… 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 >

CFPB holds field hearing on proposed rules for prepaid accounts

Posted in CFPB Rulemaking

Ballard Spahr to hold a webinar on the proposal at 12 p.m. ET on December 12th. A link to register is available here. Yesterday I attended the Consumer Financial Protection Bureau’s (CFPB) field hearing in Wilmington, Delaware, at which the CFPB unveiled and accepted public comment on its long-awaited proposed rule for prepaid accounts under the… More >

CFPB issues snapshot of debt collection complaints filed by older consumers

Posted in CFPB Rulemaking, Debt Collection

The CFPB’s Office of Older Americans has issued a report titled “a snapshot of debt collection complaints submitted by older consumers,” which provides information drawn from complaints submitted to the CFPB from July 2013 to September 2014.  For purposes of the report, a complaint submitted by an “older consumer” is one that was submitted by… More >

Leading industry trade groups comment on HMDA/Reg. C proposal

Posted in CFPB Rulemaking, Mortgages

Six leading industry trade groups have submitted a letter commenting on the CFPB’s proposed rule amending Regulation C to expand Home Mortgage Disclosure Act data reporting requirements.  The trade groups consist of the Consumer Bankers Association, Mortgage Bankers Association, American Bankers Association, Consumer Mortgage Coalition, Financial Services Roundtable and Housing Policy Council. In the letter,… More >

Senator Crapo seeks information on CFPB’s regulatory streamlining efforts

Posted in CFPB Rulemaking

In our blog post yesterday about the CFPB’s final rule allowing an alternative online delivery method for annual privacy notices, we commented that the CFPB has made limited progress on its regulatory streamlining initiative launched in December 2011.  The CFPB’s streamlining efforts were also the subject of a letter sent to Director Cordray yesterday by Senator Mike… More >

CFPB finalizes amendments to mortgage rules

Posted in CFPB Rulemaking, Mortgages

The CFPB has issued a final rule amending certain provisions of the 2013 Title XIV final mortgage rules.  While in its press release the CFPB describes the amendments as “minor adjustments to its mortgage rules,” the final rule contains several major changes from the CFPB’s proposal. QM Points and Fees Cure.  Generally, to be considered a… More >

CFPB issues final rule allowing alternative online delivery method for annual privacy notices

Posted in CFPB Rulemaking, Privacy

Nearly three years after identifying the Gramm-Leach-Bliley Act (GLBA) annual privacy notice requirement as a candidate for streamlining, the CFPB issued a final rule earlier this week to allow financial institutions that meet certain requirements to deliver such notices using an alternative online delivery method.  The rule will be effective immediately upon its publication in… 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 >

CFPB Provides Guidance on the New Loan Estimate

Posted in CFPB General, CFPB Rulemaking

On October 1, 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 Loan Estimate and addressed specific questions regarding the… More >

CFPB’s Rulemaking Process Gets Good Report Card from OIG Report with Only Minor Criticisms

Posted in CFPB Rulemaking

A September 29, 2014 Report of the Joint Federal Reserve/CFPB Office of the Inspector General (OIG) concluded that the CFPB’s rulemaking process generally complies with the requirements of Section 1100G of the Dodd-Frank legislation and offered only minor criticisms identifying potential improvements. Section 1100G amended the Regulatory Flexibility Act to require the Bureau to (A)… More >

Industry trade groups provide recommendations to CFPB on TILA-RESPA implementation

Posted in CFPB General, CFPB Rulemaking

Sixteen industry trade groups, including the American Bankers Association, the Mortgage Bankers Association, and Financial Services Roundtable, have sent a letter to Director Cordray in which they requested that the CFPB provide additional guidance to help the mortgage industry implement the new TILA-RESPA Integrated Disclosures Rule that will become effective on August 1, 2015. In… More >

CFPB issues updated guides on the TILA-RESPA Integrated Disclosure Rule

Posted in CFPB General, CFPB Rulemaking

CFPB Issues Updated Guides on the TILA-RESPA Integrated Disclosure Rule The CFPB has released its updated Small Entity Compliance Guide for the TILA-RESPA Integrated Disclosure Rule and Guide to the Loan Estimate and Closing Disclosure.  These resources replace the editions that were published in the spring of 2014. The CFPB also issued a disclosure timeline… More >

HMDA proposed rule published in Federal Register

Posted in CFPB Rulemaking, Mortgages

The proposed rule amending the Home Mortgage Disclosure Act and its implementing regulation, Regulation C, was published in the Federal Register today. As such, the official comment deadline will be October 29, 2014. We previously published a short description and analysis of the proposed rule that noted a different comment date. Our Mortgage Banking Group… More >

CFPB Answers FAQ on the TILA-RESPA Integrated Disclosures Rule

Posted in CFPB General, CFPB Rulemaking

On August 26, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar and addressed questions about the final TILA-RESPA Integrated Disclosures Rule that will be effective for applications received by creditors or mortgage brokers on or after August 1, 2015.  The webinar is the second in a planned series intended to address the… More >

NCRC white paper seeks expansive CFPB rulemaking on small business lending data collection

Posted in CFPB Rulemaking, Fair Lending

The National Community Reinvestment Coalition (NCRC) has issued a white paper that urges the CFPB to take an expansive approach in developing regulations on the collection of small business lending data to implement Section 1071 of Dodd-Frank.  Section 1071 amended the Equal Credit Opportunity Act to require financial institutions to collect and maintain certain data… More >

CFPB extends comment period on proposal to publicly disclose consumer complaint narratives

Posted in CFPB General, CFPB Rulemaking, Hot Issues

The CFPB is extending the comment period on its proposed policy statement that would expand the complaint data that it publicly discloses in its Consumer Complaint Database to include “unstructured” complaint narratives.  In a statement released on July 29, 2014, the CFPB states that it is extending the deadline for comments to be filed from… More >

CFPB Provides Guidance on Ability to Repay Rule Application to Assumptions of Residential Mortgage Loans

Posted in CFPB General, CFPB Rulemaking, Mortgages

On July 8, 2014 the CFPB provided guidance on the application of the Regulation Z ability to repay rule (section 1026.43) to assumptions of residential mortgage loans for purposes of clarifying the application of the rule in cases in which a relative acquires title to a security property upon the death of the borrower and… More >

CFPB: Industry should “start now” to comply with workplace diversity and inclusion standards

Posted in CFPB People, CFPB Rulemaking, Diversity and Inclusion

On June 26, 2014, I participated in a panel presentation at the MBA Strategic Markets and Diversity Summit, in Washington, D.C. Stuart Ishimaru, Director of the Consumer Financial Protection Bureau’s Office of Minority and Women Inclusion, also sat on the panel. The presentation focused on Section 342 of the Dodd-Frank Act and the proposed Interagency… More >

CFPB Provides Guidance on the TILA-RESPA Integrated Disclosures Rule

Posted in CFPB General, CFPB Rulemaking, Federal Agencies, Hot Issues

On June 17, 2014, the CFPB staff and Federal Reserve co-hosted a webinar on the final TILA-RESPA Integrated Disclosures Rule that will be effective for applications received by creditors or mortgage brokers on or after August 1, 2015.  The webinar is the first in a planned series intended to help creditors, mortgage brokers, settlement agents,… More >

CFPB confirms plans for auto finance larger participant rule in rulemaking agenda

Posted in Auto Finance, CFPB Rulemaking, Debt Collection, Deposit Advance Loans, Payday Lending, Prepaid Cards

In the latest semi-annual update of its rulemaking agenda, the CFPB officially confirmed that it plans to propose a rule to define “larger participants of a market for auto lending.”  The official confirmation follows statements made by Steven Antonakes at a Consumer Bankers Association meeting in April 2014 that the CFPB’s next larger participant rule… More >