Subtitle A of Title V of the Gramm-Leach-Bliley Act (GLB Act), captioned “Disclosure of Nonpublic Personal Information,” limits the instances in which a financial institution may disclose nonpublic personal information about a consumer to nonaffiliated third parties and requires financial institutions to provide certain privacy notices to their consumers and customers. Prior to July 21, 2011, rulemaking authority for the privacy provisions of the GLB Act was shared by eight Federal agencies: the Board of Governors […]
Month: January 2012
RESUBMITTING HMDA DATA
Right now HMDA reporting banks across the nation are checking, double-checking, scrubbing and reviewing their HMDA data. Some will find errors. Correcting errors before the data has been submitted to your regulator is a fairly easy task. But when examiners, auditors or others find errors in data previously submitted to regulators how do you correct those prior year errors? Assume your calendar year 2010 HMDA data was submitted on schedule by March 1, 2011. During […]
THE CFPB INHERITS REGULATIONS N and O
Congress enacted section 626 of the Omnibus Appropriations Act (Omnibus Appropriations Act) on March 11, 2009 and directed the Federal Trade Commission (FTC) to commence a rulemaking proceeding within 90 days of enactment with respect to mortgage loans. On May 22, 2009, the enactment of the Credit Card Accountability Responsibility and Disclosure Act clarified the FTC’s rulemaking authority under the Omnibus Appropriations Act to specify that the FTC’s rulemaking based on its authority pursuant to the Omnibus […]
THE CFPB INHERITS REGULATION M
The Consumer Leasing Act (CLA) was enacted in 1976 as an amendment to the Truth in Lending Act (TILA). The purpose of the CLA is to ensure meaningful and accurate disclosure of the terms of personal property leases for personal, family, or household use. The CLA and Regulation M require lessors to provide consumers with uniform cost and other disclosures about consumer lease transactions. The CLA has been implemented in Regulation M of the Board of […]
THE CFPB INHERITS REGULATIONS J, K, & L
The Interstate Land Sales Full Disclosure Act (ILSA) protects consumers by requiring certain land developers to register their plans and to provide prescribed disclosures to prospective purchasers. Developers of subdivisions with one hundred or more nonexempt lots, and developers of condominiums with one hundred or more nonexempt units, must register development plans with the Federal regulator designated by ILSA. These developers must also provide purchasers with a comprehensive disclosure statement known as a property report […]