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Senators introduce bill to increase “large bank” asset threshold for CFPB supervision

Posted in CFPB Exams

A bipartisan bill (S. 2732) has been introduced by Republican Senator Pat Toomey and Democratic Senator Joe Donnelly to increase the asset threshold for “large banks” that are subject to CFPB supervision.

The current threshold is total assets of more than $10 billion.  Entitled the “Consumer Financial Protection Bureau Examination and Reporting Threshold Act of 2014,” the bill would increase the current threshold to assets of more than $50 billion.  The higher threshold would be substantially the same as the threshold for a bank to be designated “systemically important” (i.e., assets of $50 billion or more).

Senator Crapo raises concerns with Department of Education campus financial product rulemaking

Posted in Campus Financial Products

Republican Senator Mike Crapo, Ranking Member of the Senate Committee on Banking, Housing, and Urban Affairs, sent a letter last week to Department of Education (ED) Secretary Arne Duncan to raise several concerns with the ED’s Title IV rulemaking efforts.  Earlier this year, the ED engaged in negotiated rulemaking, with the CFPB among the those participating in support of the rulemaking.  Negotiated rulemaking did not reach a consensus, and the ED is expected to soon be issuing its proposal. 

In his letter, Senator Crapo raises the concern shared by many observers that the ED’s proposal will include significant new restrictions on products that banks sell to college students, even if the product is not specifically designed to distribute financial aid.  He observes that in the negotiated rulemaking, the ED proposed a definition of a “sponsored account” that would include any financial account that “an enrolled student or parent of an enrolled student may choose to open, obtain, or use…to receive Title IV, HEA program funds.”  He points out because the definition “could include a basic bank account set-up by a student during freshman orientation that never receives or was intended to receive Title IV funds,” it would be impossible for banks to know which account is a “sponsored account” and lead to a presumption that most accounts held by college students are “sponsored accounts” subject to the ED’s regulations.  He expresses concern that “such an expansive approach exceeds the [ED's] statutory authority under the HEA and will interfere with the prudential banking regulation of such financial products.” 

Senator Crapo also comments that based on outreach from his office to the federal banking regulators, the ED completed the negotiated rulemaking process “without a single consultation with prudential banking regulators even though the very product the [ED] is proposing to regulate—a consumer’s checking account—is subject to [a] myriad of existing Federal and state laws.”  He notes his concern that the ED has taken policy positions “without giving due regard to the current regulatory framework” which could lead to “inconsistent and confusing compliance regimes for financial institutions, supervisory challenges for Federal and state banking regulators, and to unintended consequences that may in the end limit student choice and convenience.” 

Finally, Senator Crapo expresses concern with the proposal’s timing.  He notes that the ED has said it intends to move quickly to have a final rule in place for next year.  According to Senator Crapo, because the ED would have to finalize its rule by November 1, 2014 for it to become effective in July 2015, this might not allow sufficient time for the ED to obtain and consider stakeholder input.  Commenting that “it is more important to get the rule right” than to finalize it by November 1, he states that the rule’s magnitude and complexity warrants a 90-day comment period.

 

CFPB publishes annual CARD Act, HOEPA and QM adjustments

Posted in Credit Cards, Mortgages

The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank.  The adjustments made by the final rule are effective January 1, 2015. 

The CARD Act requires the CFPB to calculate annual adjustments of (1) the minimum interest charge threshold that triggers disclosure of the minimum interest charge in credit card applications, solicitations and account opening disclosures, and (2) the fee thresholds for the penalty fees safe harbor.  The calculation did not result in a change to the current $1.00 minimum interest charge threshold.  However, in the final rule, the CFPB increased the current penalty fee safe harbor of $26 for a first late payment and $37 for a subsequent violation within the following six months to, respectively, $27 and $38. 

HOEPA requires the CFPB to annually adjust the total loan amount threshold that determines whether a transaction is a high cost mortgage when the points and fees are either 5 percent or 8 percent of such amount.  In the final rule, the CFPB increased the current dollar thresholds from, respectively, $20,000 to $20,391, and $1,000 to $1,020.  

Pursuant to its ability to repay/QM rule, the CFPB must annually adjust the points and fees limits that a loan must not exceed to satisfy the requirements for a QM.  The CFPB must also annually adjust the related loan amount limits.  In the final rule, the CFPB increased these limits to the following :

  • For a loan amount greater than or equal to $101,953 (currently $100,00), points and fees may not exceed 3 percent of the total loan amount
  • For a loan amount greater than or equal to $61,172 (currently $60,000) but less than $101,953 (currently $100,000), points and fees may not exceed $3,059 (currently $3,000)
  • For a loan amount greater than or equal to $20,391 (currently $20,000) but less than $61,172 (currently $60,000), points and fees may not exceed 5 percent of the total loan amount
  • For a loan amount greater than or equal to $12,744 (currently $12,500) but less than $20,391 (currently $20,000), points and fees may not exceed $1,020 (currently $1,000)
  • For a loan amount less than $12,744 (currently $12,500), points and fees may not exceed 8 percent of the total loan amount

CFPB settles with military base retailer for alleged fee scam; Senators seek CFPB investigation of retailer’s debt collection practices

Posted in CFPB Enforcement, Military Issues

The CFPB has announced a settlement with USA Discounters, a retailer that operates a chain of stores near military bases and offers financing for purchases through retail installment sales contracts (RICs), to resolve charges involving an alleged fee scam.  The consent order requires USA Discounters to make refunds to servicemembers of more than $350,000 and pay a $50,000 civil money penalty.  In the consent order, USA Discounters does not admit or deny “any findings of fact or violations of law” but does admit “the facts necessary to establish the CFPB’s jurisdiction over USA Discounters and the subject matter of this action.”

According to the consent order, the CFPB found that, to enter into a RIC with USA Discounters, an active duty servicemember had to agree to pay a $5 fee for a company called SCRA Specialists LLC to be the servicemember’s representative with respect to his or her rights under the Servicemembers Civil Relief Act (SCRA).  USA Discounters was found to have portrayed SCRA Specialists as an independent representative that would be available to receive notices of lawsuits filed by USA Discounters, inform USA Discounters of a change in the servicemember’s address, and verify the servicemember’s military status to determine whether the servicemember was eligible for protection under the SCRA.

The CFPB concluded that USA Discounters had engaged in unfair and deceptive acts and practices by conduct that included:

  • telling servicemembers that it would use SCRA Specialists to verify the servicemember’s active military status  and marketing this verification as a benefit, when in fact, USA Discounters was required by the SCRA to verify the servicemember’s military status to obtain a default judgment against the servicemember and routinely performed its own duty status verifications
  • misleading servicemembers into believing they would have an independent representative when, in fact, SCRA Specialist received all of its revenue from USA Discounters’ customers and did not provide any representational services to servicemembers
  • failing to provide the services that were promised in exchange for the $5 fee paid by servicemembers

The more than $350,000 in refunds that USA Discounters must make under the Consent Order is based on the CFPB’s finding that since 2009, the $5 fee was charged in more than 70,000 contracts which generated more than $350,000.  For consumers with repaid RICs, USA Discounters must send them a check for the full $5 plus interest and for consumers with accounts in collection, USA Discounters must deduct the $5 fee plus interest from the account balance.

In addition to requiring payment of the refunds and the $50,000 penalty, the Consent Order prohibits USA Discounters from engaging in the challenged practices, offering the performance for a fee of any SCRA-related service involving a RIC for which USA Discounters is a creditor or assignee, and accepting any payment in exchange for the performance of any such service.

While the CFPB obviously believes it has enforcement authority over USA Discounters, and the Consent Order contains USA Discounter’s admission of the facts necessary to establish the CFPB’s jurisdiction, it is worth noting that Dodd-Frank Section 1027(a) limits the CFPB’s rulemaking, supervisory and enforcement authority as to retailers of “nonfinancial goods or services.”  That provision, however, is one of the most confusing provisions of Dodd-Frank Title 10.

The provision contains an exclusion from CFPB authority for retailers of nonfinancial goods or services to the extent the retailer “extends credit directly to a consumer…exclusively for the purpose of enabling that consumer to purchase such nonfinancial good or service directly from” the retailer.  It also states that the exclusion does not cover credit transactions arising from a transaction in which a retailer “of nonfinancial good or services regularly extends credit and the credit is subject to a finance charge.”  However, it further states that despite this limitation on the exclusion, a retailer “that is not engaged significantly in offering or providing consumer financial products or services” continues to be excluded from CFPB authority.  Thus, while USA Discounters may not have been able to take advantage of the retailer exclusion, the scope of the exclusion will undoubtedly be an issue in any CFPB enforcement efforts directed at a retailer.  (Of course, a retailer that is  not subject to the CFPB’s UDAAP enforcement authority would still be subject to the FTC’s UDAP enforcement authority.)

Despite agreeing to the Consent Order, USA Discounters could find itself the subject of further CFPB scrutiny as a result of a letter sent earlier this month to Director Cordray and Defense Secretary Hagel by a group of five Democratic Senators that urges the CFPB and Department of Defense (DOD) to investigate claims made in a recent report from ProPublica and the Washington Post that “certain retailers have undertaken aggressive debt collection actions against active duty servicemembers without affording them, arguably, a real opportunity to defend themselves.”

According to the Senators, the media has reported that certain retailers “may have violated the spirit” of the SCRA by including ” a provision in the fine print of their contracts that allow the retailers to bring suit against servicemembers in certain jurisdictions in the Commonwealth of Virginia, even though they may not be based there or, in fact, ever have been based there.”  The Senators asserted that the retailers have used such provisions to “force involuntary garnishment of servicemembers’ wages while they are serving our country.”

In addition to calling on the CFPB and DOD to investigate these claims, the Senators asked the CFPB and DOD to determine what actions can be taken to “ensure due process for our servicemembers, especially the practice of including contractual provisions that may limit servicemembers’ ability to defend themselves while they are on active duty.”

 

Media reports on student loan debt: distortions abound

Posted in Student Loans

Two recent articles highlight how student loan debt is often the subject of distorted reporting. 

An article from Hamilton Place Strategies observed that news stories often include anecdotal stories about families burdened by student debt.  After examining about 100 articles with such stories over a three month period, the authors found that the new stories “are distinctly unrepresentative of the actual facts about student debt.”  

According to the authors, while the news coverage reported an average student debt level of $85,400, government statistics for 2012 graduates indicated average debt of $29,400.  They noted that this means the average debt level reported through anecdotes represents the 98th percentile of all who have debt.  They commented that “this would be the statistical equivalent of surveying a selected group of American workers, finding an average income level of $360,000 and therefore reporting that the economy is doing well.”   They also stated that the greatest concern with this skewed news coverage is its potential to impact aspiring students making decisions based on such coverage.  More specifically, the authors fear potential students may “get the incorrect impression that a degree is not worth it and they take a pass on higher education all together.” 

A second article posted on Slate.com takes aim at a blog post that commented on a recent report from Goldman Sachs analysts.  After looking into whether student loans were keeping millennial from becoming homeowners, the analysts concluded that having student debt does not necessarily hurt housing.  The Slate author observed that, despite this conclusion, the blog post carried the headline “How student debt crushes your chances of buying a home.”  

The Slate author aptly commented that “Something had been lost in translation.”  He noted that on the whole, the Goldman report found that graduating from college, with or without debt, makes it easier to buy a house than if someone only finished high school and that, in most cases, owing student loans did not meaningfully change the chances that someone would buy instead of rent.   He also observed that while the Goldman report found that households between the ages of 25 and 34 with more than $50,000 in loans were 8 percentage points less likely to own a home than those with smaller debt burdens, it also found that based on the Federal Reserve’s Survey of Consumer Finances, only about 17 percent of all households with student loans have debt levels above $50,000.  In addition, while the Goldman report found that former students who spent more than 10 percent of their monthly income servicing their debt were 22 percentage points less likely to be homeowners, such students represent a minority of borrowers (with only 9 percent of households with student debt devoting one-tenth or more of their income toward loans).  

The Slate author concluded with the observation that “on the whole, there are probably much more important reasons [than student loan debt]—including the slow job market, which has been especially brutal on the young—that are preventing millennials from buying houses.”

CFPB announces settlement with mortgage lender and its owner charged with “bait-and-switch” scheme

Posted in CFPB Enforcement, Mortgages

On August 12, the CFPB announced that it has issued a Consent Order under which Atlanta-based Amerisave Mortgage Corporation, its affiliate appraisal management company, Nova Appraisal Management Company, and a principal and indirect owner of both companies, Patrick Markert, agreed to pay nearly $21 million for deceiving and overcharging consumers in a bait-and-switch mortgage-lending scheme.  The companies and principal did not admit or deny the CFPB’s findings of fact or conclusions of law.

According to the CFPB’s press release, “Amerisave lured consumers by advertising misleading interest rates, locked them in with costly up-front fees, failed to honor its advertised rates, and then illegally overcharged them for [undisclosed] affiliated “third-party” services.”

Between mid-2011 and 2014, the CFPB said, Amerisave advertised its interest rates and terms in all 50 states and the District of Columbia using banner ads and rate tables on third-party websites.  According to the CFPB, these advertisements were inaccurate, and when consumers were directed to Amerisave’s own website, the company advertised interest rates based on an 800 credit score quote, even when the majority of consumers had already entered their own lower credit scores on the third-party websites that led them to Amerisave.  The fact that the mortgage quote was actually based on an 800 credit score was not disclosed to consumers until after they began a mortgage application.

In addition, the Consent Order states that from at least January 2009 to May 2011, Amerisave charged consumers a $35 fee at the outset of a mortgage application, before Amerisave provided them with a GFE and the consumer indicated an intent to proceed.  Although the CFPB cited the upfront fee restrictions under Regulation X and Regulation Z that apply to residential mortgage loans, the CFPB did not note that the Regulation X restriction applies to applications received on or after January 1, 2010 and the Regulation Z restriction applies to applications received on or after July 30, 2009.  It appears that in referring to a “GFE” the CFPB is referring to the Good Faith Estimate under Regulation X and the initial TILA disclosure under Regulation Z.  But in certain cases the CFPB is not clear regarding what conduct in its view violated which specific restriction under the Regulations.

The CFPB alleges that before the Regulation Z prohibition on imposing upfront fees beyond a bona fide and reasonable credit report fee became effective, the upfront $35 fee charged by Amerisave was an application fee.  Then, around the time the  prohibition became effective, the $35 fee was charged as a credit report deposit fee.  The CFPB asserts that during this time, individual and joint credit reports actually cost Amerisave only $7.50 and $12, respectively.

The CFPB asserts that Amerisave also required consumers to order and authorize a $375 to $500 payment for an appraisal from Novo before receiving a GFE.  The Consent Order states that Amerisave did not disclose Novo’s affiliation or that there was a 24 hour cancellation fee of 50% until after the consumer had authorized payment and at Amerisave’s encouragement, scheduled the appraisal for “as soon as possible.”

Addressing the effect on consumers, the CFPB states in the press release that “By leading customers to believe that they were already obligated to pay such costly fees, often $400 or more, Amerisave restricted consumers’ ability to shop for alternative products and better prices.”   In the Consent Order, the CFPB asserts that “By marking up the cost of credit reports and requiring appraisal fee credit or debit card authorizations before giving consumers their first GFE and receiving an indication of the consumer’s intent to proceed with a loan covered by the GFE, Amerisave violated RESPA, Regulation X and TILA, Regulation Z.”

As we have previously covered, in Freeman, et al. v. Quicken Loans, Inc., the United States Supreme Court ruled that RESPA section 8 does not prohibit a single service provider from marking up the cost of a settlement service, such as a credit report.  Potentially, the CFPB markup position is based on the upfront fee restrictions in Regulation X and Regulation Z.  In particular, the Regulation Z restriction expressly requires that an upfront credit report fee be bona fide and reasonable.  While HUD added an upfront fee restriction to Regulation X, RESPA does not provide for such a restriction or limit the amount of fees charged.  If the CFPB were to assert that the Regulation X upfront fee restriction prohibits markups, we are not sure that a court would find that approach to be acceptable.

Finally, the CFPB asserted that Amerisave charged consumers $100 at closing for “appraisal validation” reports without disclosing that the service was provided by Novo, and that the reports were marked up by as much as 900%.   Apparently based on its assertion that Amerisave referred appraisal-related business to Novo without disclosing the nature of its relationship with Novo to consumers, the CFPB concluded that the companies were not entitled to rely on the affiliated business arrangement exception to the RESPA referral fee prohibition.

Amerisave and Novo consented to refund $14.8 million to consumers and pay $4.5 million in civil money penalties.  In addition, Markert agreed to pay a $1.5 million civil money penalty.  However, Markert is jointly and severally liable with the companies to pay the full amount of the damages and civil money penalties.  In connection with any redress to affected consumers, the Consent Order prohibits a redress payment from being conditioned on a consumer’s waiver of any rights. 

Additionally, among other provisions, the Consent Order (1) bars Amerisave from advertising unavailable mortgage rates and requires various procedures to provide for accurate advertisements, (2) requires that Amerisave provide an affiliated business arrangement disclosure before making referrals, or requiring the use (when permitted), of an affiliate, (3) prohibits Amerisave from charging any fee other than the actual cost of a credit report before providing a GFE and affiliated business arrangement disclosure and the consumer has indicated an intent to proceed, and (4) prohibits Amerisave from scheduling an appraisal or otherwise making any referral of third party services (other than for a credit report) until it has provided a GFE and, in the case of referrals to or a permitted required use of an affiliate, an affiliated business arrangement disclosure.

The prohibition on the ordering of an appraisal may be viewed with concern by the industry.  While the upfront fee restrictions bar charging a consumer for an appraisal before the consumer has received initial disclosures and indicated an intent to proceed, they do not expressly prohibit the ordering of an appraisal (although care must be taken to avoid suggesting to a consumer that they would be responsible for the cost even if they do not proceed with the transaction).

 

CFPB issues consumer advisory on virtual currencies and begins taking virtual currency complaints

Posted in Hot Issues

In conjunction with issuing a consumer advisory today on virtual currencies, the CFPB announced that it is now taking complaints about virtual currency products and services.  The CFPB’s actions follows the issuance of a report by the Government Accountability Office in June 2014 in which the GAO recommended increased CFPB participation in interagency efforts related to such currencies.

In the CFPB’s press release, Director Cordray described virtual currencies as “stepping into the Wild West.”

The advisory explains virtual currencies and discusses associated risks that consumers should be aware of.  (Bitcoin is the most well-known of the virtual currencies.)  Such risks include unclear costs, volatile exchange rates, the threat of hacking and scams (including when a consumer’s bank account and virtual currency account are linked), the unavailability of help or refunds for lost or stolen funds from virtual currency companies, and the absence of government insurance for virtual currency accounts.

In November 2013, Mercedes Kelley Tunstall, who leads Ballard Spahr’s Privacy and Data Security Group, testified on virtual currencies before two subcommittees of the U.S. Senate Committee on Banking, Housing and Urban Affairs.  Mercedes advises banking clients nationwide on payments and cybersecurity issues, including those involving virtual currencies.  At the hearing, she addressed the commercial viability of digital currencies, regulatory options, and how to respond to other emerging virtual currencies.

The CFPB’s announcement that it is now taking complaints about virtual currencies represents the second expansion of the CFPB’s complaint system announced this summer.  Last month, the CFPB announced that it had begun taking complaints from consumers about prepaid cards, such as gift cards, benefit cards, and general purpose reloadable cards, debt settlement services, credit repair services, and pawn and title loans.

 

 

 

 

 

CFPB calls out banks for not publicly disclosing campus financial product marketing agreements

Posted in Campus Financial Products

According to a new blog post about “secret banking contracts” by Rohit Chopra, the CFPB’s Student Loan Ombudsman, the CFPB is sending letters to colleges and universities “to make sure they know that their bank partner has not yet committed to transparency when it comes to student financial products” because it has not yet posted its marketing agreement with the school on its website.   

Last December, in a “call for transparency,” the CFPB urged financial institutions to publicly disclose their marketing agreements for campus financial products other than credit cards, such as deposit accounts, prepaid cards and financial aid disbursement accounts.  That call was accompanied by the threat that a financial institution’s failure to disclose its campus marketing agreements could make it a target for examination. 

In its letters, the CFPB tells schools with such marketing agreements that “[b]ased on a scan of your financial institution partner’s website, it appears that [name of financial institution] has not disclosed this agreement.  We wanted to alert you that this failure to be transparent may pose potential consumer protection risks.” 

In his new blog post, Mr. Chopra states that at least 13 of the 14 Big Ten schools have entered into arrangements with banks to market financial products to students.  He states that of those 13, the CFPB could “easily find only four contracts on the partner websites, but three of those four contracts did not contain important information, such as how much they pay schools to gain access to students in order to market and sell them financial products and services.” 

 

OCC consumer protection standards in new Bulletin may influence CFPB Debt Sales Examinations of Banks

Posted in CFPB General

As noted in our recent Alert, the Office of the Comptroller of the Currency (OCC) has issued Bulletin 2014-37 on Consumer Debt Sales (the “Bulletin”). The Bulletin addresses the application of consumer protection requirements and safe and sound banking practices to debt sales by OCC-supervised institutions (national banks and federal thrifts) of all sizes, including community banks. The OCC’s guidance on consumer protection may well prove influential when it comes to CFPB examinations of banks within its jurisdiction — and possibly of nonbank entities as well — in the debt sales area, as well as further action by the CFPB on this subject.

These are areas in which the CFPB is keenly interested. Already, as we have previously noted, the Bureau’s Spring 2014 Supervisory Highlights Report has identified as serious problems both the failure of a debt seller to assess a debt buyer’s compliance with federal consumer laws and the alleged frequency of sales of previously cancelled debts. Moreover, since last Fall, the CFPB has been engaged in a rulemaking proceeding dealing, inter alia, with third-party debt collection practices.

OCC has identified in the Bulletin a laundry list of items that OCC-supervised institutions are required to provide (apparently at the time of sale) to debt buyers:

• A copy of the signed contract or other documents that provide evidence of the relevant consumer’s liability for the debt in question.
• Copies of all, or the last 12 (whichever is fewer), account statements.
• All account numbers used by the bank (and, if appropriate, its predecessors) to identify the debt at issue.
• An itemized account of all amounts claimed to be owed in connection with the debt to be sold, including loan principal, interest, and all fees.
• The name of the issuing bank and, if appropriate, the store or brand name.
• The date, source, and amount of the debtor’s last payment and the dates of default and amount owed.
• Information about all unresolved disputes and fraud claims made by the debtor.
• Information about collection efforts (both internal and third-party efforts, such as by law firms) made through the date of sale.
• The debtor’s name, address, and Social Security number.

While the OCC advises that minimum service level agreements should also be incorporated into debt sale agreements, no specific standards for inclusion are identified in the Bulletin.

The CFPB may well seek to impose enhanced or additional requirements.

Under the Bulletin, certain kinds of debt are deemed “clearly not appropriate for sale” for their failure to meet the basic requirements to constitute an ongoing legal debt. These include:

o debts that are in litigation;
o debts that have been settled or are in the process of settlement;
o debts of deceased debtors; and
o accounts “lacking clear evidence of ownership.”

In addition, the Bulletin instructs that banks should “refrain” from selling—

o accounts in disaster areas,
o SCRA accounts,
o accounts of minors, and
o accounts “close to the statute of limitations.”

In this last category, however, the OCC provides no further direction on how “close” an account must be to the expiry of the statute of limitations in order for the sale to a debt buyer to be considered improper.

We would not be surprised to see the Bureau, by order or regulation, endorse these items and perhaps add some of its own.

Moreover, we note that, in the Bulletin, the OCC was careful to note that its new guidance does not create any new legal rights against a bank that sells debt, either for a consumer whose debt is sold or for any other third party. It will be important, should the CFPB issue orders or engage in rulemaking in this area, for that agency to include a similarly explicit limitation.

Finally, at the very end of the Bulletin, the OCC observes, “When the OCC becomes aware of concerns with nonbank debt buyers, the agency refers those issues to the CFPB, which has jurisdiction over these entities.” This may be a harbinger of increased numbers of CFPB investigations of nonbank debt collectors growing out of the OCC’s now heightened scrutiny of debt sales by national banks and federal thrifts.

Ballard Spahr will host a webinar on the Bulletin on September 24, 2014, from 12 – 1 p.m. EST.

Second CFPB/Fed webinar on TILA-RESPA integrated disclosures scheduled for August 26

Posted in Mortgages

On August 26, 2014, the CFPB and Federal Reserve will be co-hosting the second of a series of webinars on the TILA-RESPA integrated mortgage loan disclosures rule.  The first webinar, which was held on June 17, provided an overview of the final rule and new disclosures.

The description of the second webinar indicates that it “will address specific questions related to rule interpretation and implementation challenges that have been raised to the Bureau by creditors, mortgage brokers, settlement agents, software developers, and other stakeholders.”

A link to register is available here.