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Category Archives: CFPB General

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CFPB Jan. 2016 complaint report highlights “other financial service” complaints, complaints from NY State/NY metro area consumers

Posted in CFPB General

The CFPB has issued its January 2016 complaint report which highlights “other financial service” complaints and complaints from consumers in New York State and the New York metro area.  In addition to the major complaint categories consumers can use when submitting online complaints to the CFPB, there is a miscellaneous category labeled “other financial service.” … More >

CFPB seeking new members for advisory groups

Posted in CFPB General

The CFPB has published notices in the Federal Register announcing that it is seeking applications from persons interested in becoming members of its Academic Research Council (ARC), Consumer Advisory Board (Board), Community Bank Advisory Council (CBAC), or Credit Union Advisory Council (CUAC). Appointments to the ARC and Board are typically for three years and appointments… More >

CFPB using Google ads to solicit consumer complaints

Posted in CFPB General

In an effort to publicize its online complaint system and bring in more complaints, the CFPB is now soliciting complaints through Internet advertising.  When browsing the Internet recently, we came across the following which appeared to be a Google ad placed by the CFPB: The ad links to the “Submit a complaint” page on the CFPB’s… More >

CFPB issues third appropriations report

Posted in CFPB General

The CFPB has issued its third report entitled “Report of the Consumer Financial Protection Bureau Pursuant to Section 1017(e)(4) of the Dodd-Frank Act.”  That Dodd-Frank section requires the CFPB’s Director to submit an annual report to the House and Senate Committees on Appropriations “regarding the financial operating plans and forecasts of the Director, the financial… More >

CFPB outlines exam priorities for 2016

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

The CFPB’s Deputy Assistant Director for origination recently warned mortgage lenders of the four main examination priorities for 2016—loan originator compensation plans, the ability-to-repay rule, the TILA-RESPA Integrated Disclosures (TRID) rule, and marketing service agreements. Speaking at the California MBA Legal Issues Conference, Calvin Hagins indicated that CFPB examiners will spend a substantial amount of… More >

House Financial Services Committee to hold December 16 hearing on CFPB data collection

Posted in CFPB General

The House Financial Service Committee’s Subcommittee on Oversight and Investigations has scheduled a hearing for December 16, 2015 on “Examining the Consumer Financial Protection Bureau’s Mass Data Collection Program.” The witnesses scheduled to appear are:  Newt Gingrich, former House Speaker, Wayne Abernathy, American Bankers Association Executive Vice President for Financial Institutions Policy and Regulatory Affairs,… More >

Is Online Lead Generation Inherently Deceptive?

Posted in CFPB General, FTC, Hot Issues, Lead Generation, Payday Lending

This post is the third in a series we’re writing on the FTC’s workshop on online lead generation entitled Follow the Lead. In our first post, we explored how online lead generation works. In our second, we covered the role that disclosures can and should play. Here, we will discuss the allegation the CFPB and certain consumer… More >

CFPB’s Ombudsman’s Office issues fourth annual report

Posted in CFPB General

The CFPB’s Ombudsman’s Office has issued its fourth annual report covering the Office’s activities during fiscal year 2015 (October 1, 2014 through September 30, 2015).  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. The… More >

Director Cordray responds to American Banker article

Posted in CFPB General

Two weeks ago, we reported on an article published by the American Banker, which alleged certain inaccuracies and flawed practices in the CFPB’s consumer complaint database, citing several current and former employees of the Bureau. This week, CFPB Director Richard Cordray wrote a sharp rebuke of the American Banker’s article, claiming that it was  “riddled… More >

Mobile Financial Services and the Underserved

Posted in CFPB General

The CFPB recently released a report regarding the use of Mobile Financial Services by underserved populations, including low-income, unbanked, underbanked, and economically vulnerable consumers. The report does not contain any findings or specific recommendations; rather, it is a summary of public comments received in response to the Request for Information issued in June 2014 by… More >

CFPB issues eighth Semi-Annual Report

Posted in CFPB General

The CFPB has issued its eighth Semi-Annual Report to the President and Congress covering the period from April 1, 2015 through September 30, 2015. The 190-page report recycles information from previously-issued CFPB reports and reviews ongoing and past developments, which we have covered in previous blog posts. By way of aggregate statistics, the report indicates… More >

House passes bill to curb QM requirements

Posted in CFPB General, Mortgages

On November 18, 2015, the U.S. House of Representatives passed a bill that would provide a safe harbor exception for depository institutions from certain provisions of the Truth in Lending Act and Regulation Z, and for mortgage originators from the steering prohibition of the loan originator compensation requirements under Regulation Z (LO Comp Rule). By… More >

Disclosure Confusion in the Online Lead Generation Industry

Posted in CFPB General, FTC, Hot Issues, Lead Generation, UDAAP

This post is the second in a series we’re writing on the FTC’s workshop on online lead generation entitled Follow the Lead. In our first post, we explored how online lead generation works. Here, we will discuss two fundamental questions surrounding the role that disclosures can and should play in the industry: What should be… More >

American Banker claims CFPB complaint database believed to be unreliable

Posted in CFPB General

A recent article by the American Banker claims, based on undisclosed CFPB documents and interviews with current and former agency officials, that the CFPB’s consumer complaint database is widely held to be inaccurate and untrustworthy. The article points to what it believes to be egregious instances of duplicative complaints as well as the misidentification of… More >

CFPB issues FY 2015 financial report

Posted in CFPB General

The CFPB has issued its financial report for its 2015 fiscal year, which ended on September 30, 2015.  The report indicates that the number of CFPB employees grew from 1,443 in FY 2014 to 1,529 in FY 2015.  Transfers to the CFPB from the Fed (which are capped by Dodd-Frank at a pre-set percentage of… More >

CFPB Revises Supervisory Appeals Process

Posted in CFPB Enforcement, CFPB Exams, CFPB General

As we wrote last week, the CFPB recently published a Fall 2015 Supervisory Highlights which included a summary of changes that have been made to the CFPB’s supervisory appeals process. The original supervisory appeal process was published three years ago in CFPB Bulletin 2012-07. The revised supervisory appeals process incorporates a number of changes. (Note… More >

The Five Stages of Online Lead Generation

Posted in CFPB Enforcement, CFPB General, FTC, Hot Issues, Lead Generation

On October 30, the FTC presented a workshop on lead generation entitled Follow the Lead. Online lead generation is an area receiving increased regulatory scrutiny by the FTC and other regulators, including the CFPB. Over the next several days, we will be presenting a series of posts highlighting key issues in the industry and likely… More >

CFPB highlights credit card complaints in fourth monthly complaint report

Posted in CFPB General, Credit Cards

The CFPB has issued its October 2015 complaint report, the fourth in its new series of monthly complaint reports.  The new report highlights credit card complaints and complaints from consumers in the Chicago, Illinois metro area. General findings include the following: As of October 1, 2015, the CFPB handled approximately 726,000 complaints nationally, including approximately… More >


Posted in CFPB General

SPAM ALERT: Individuals have been receiving emails from a sender who is posing as Ballard Spahr Consumer Financial Services Practice Group Leader Alan S. Kaplinsky. These emails are sent as emails from a fake CFPB Monitor email address ( and provide a fake email address for Mr. Kaplinsky (    They also imply that Mr. Kaplinsky… More >

Be Careful What You Ask For, You May Get It—The CFPB Addresses Marketing Services Agreements Under RESPA

Posted in CFPB General

The residential mortgage settlement service industry has been asking the CFPB for guidance on the legality of marketing service agreements (MSAs) under RESPA. When questioned on the issue last week at a House Financial Services Committee hearing, Director Cordray indicated that the CFPB would issue guidance. One week later the CFPB has now issued non-binding… More >