On May 26, 2022, the Consumer Financial Protection Bureau (CFPB) confirmed that federal anti-discrimination law requires companies to explain to applicants the specific reasons for denying an application for credit or taking other adverse actions, even if the creditor is relying on credit models using complex algorithms. The CFPB published a Consumer Financial Protection Circular (Circular 2022-3) to remind the public, including those responsible for enforcing federal consumer financial protection law, of creditors’ adverse action notice […]
Month: May 2022
FDIC 2022 RISK REVIEW
On May 20th, the Federal Deposit Insurance Corporation (FDIC) published its 2022 Risk Review, a comprehensive summary of emerging risks in the U.S. banking system as observed in 2021. The 2022 Risk Review: Expands coverage of risks from prior reports by examining operational risk to banks from cyber threats and illicit activity, and climate-related financial risks faced by banking organizations. Provides a retrospective summary of conditions in the U.S. economy, financial markets, and banking sector, and […]
CFPB PUBLISHES SECOND SET OF PANDEMIC RESPONSE
On May 16, 2022, the Consumer Financial Protection Bureau (CFPB) published its second Mortgage Servicing COVID-19 Pandemic Response Metrics. The report provides the CFPB’s observations of data obtained from 16 large mortgage servicers to identify areas of risk in the servicers’ COVID-19 pandemic response. The report: Addresses key metrics for call center data, forbearance enrollments and exits, delinquency, and borrower profiles. Informs servicers’ own data reviews as they determine whether they are doing enough for […]
NEW INTERAGENCY QUESTIONS AND ANSWERS REGARDING FLOOD INSURANCE – FINALLY
On May 11, 2022, the Board of Governors of the Federal Reserve System, the Farm Credit Administration, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (jointly, the agencies) issued revised questions and answers (Q&As) regarding federal flood insurance law and the agencies’ implementing regulations. The Q&As: Replace those originally published by the agencies in 2009 and 2011 and consolidate Q&As proposed by the agencies […]
CFPB ISSUES ECOA ADVISORY OPINION
On May 9, 2022, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion to affirm that the Equal Credit Opportunity Act and Regulation B protect not only those actively seeking credit but also those who sought and have received credit. This is not a new position, it is a reaffirmation of long standing law and regulation. The advisory opinion is effective upon publication in the Federal Register, which is expected soon.