The Consumer Financial Protection Bureau (CFPB) has proposed thousands of pages of new rules during 2012. Everyone knows that final rules are expected soon, but it is generally not clear exactly what is going to happen and when is it going to happen. The following table summarizes what is expected from the CFPB and when the next action is expected. The information is largely based on the Spring 2012 Semiannual Regulatory Agenda published by the
UDAAP – LIST OF VIOLATIONS
Category: FDIC, UDAAP, Uncategorized
The emphasis on Unfair, Deceptive and Abusive Acts or Practices (UDAAP) is increasing. Violations are being cited with increasing frequency. The civil monetary penalties being imposed are substantial. While all of the federal regulatory agencies focus on the issue, the most intense focus seems to come from the Federal Deposit Insurance Corporation (FDIC). While all of the FDIC’s regions appear to be focusing on the issue, the most intense focus appears to be coming from
REVISED INTERAGENCY EXAMINATION PROCEDURES FOR REGULATION Z
Category: CFPB, Regulation Z, Truth in Lending
Several sources recently reported that the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council approved revised interagency examination procedures for Regulation Z – Truth in Lending. So, is this a significant event? Does your bank need to do anything in response? The primary revisions to the examination procedures result from the July 21, 2011 transfer of Regulation Z from the Federal Reserve Board to the Consumer Financial Protection Board. To minimize
DELAYED REMITTANCE RULE
Category: CFPB, Regulation E, Remittance Rule
On November 27, 2012 the Consumer Financial Protection Bureau (CFPB) announced that it is delaying the effective date of the final Regulation E Remittance Rules from February to May of 2013 to accommodate a few last minute changes. The CFPB plans to propose a narrow set of changes to address the rule’s provisions on: (1) errors resulting from incorrect account numbers provided by senders of remittance transfers; (2) the disclosure of certain foreign taxes and
RAJ DATE RESIGNS
Category: CFPB
Recently it was announced that Raj Date, the second highest ranking official at the Consumer Financial Protection Bureau (CFPB), plans to resign from the agency he helped create. Date is departing the CFPB on or around January 31, 2013 after the agency finalizes the slate of mortgage rules mandated by the Dodd-Frank Act. Mr. Date has had a long and varied career in and around U.S. financial institutions – as a strategy consultant, as a
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