CFPB DELAYS ABILITY TO REPAY RULE
Category: CFPB, Lending Compliance, Regulation Z, Truth in Lending
On May 31st the Consumer Financial Protection Bureau (CFPB) announced that it is seeking additional public comment on new data and information that it has received in a rulemaking to require lenders to revise Regulation Z to assess consumers’ ability to repay mortgage loans before extending them credit. The latest comment period will close on July 9, 2012. The CFPB is a new agency so we need to cut them a little slack. What the
In my seminars and webinars around the US I frequently refer to the community bank inferiority complex. Many community banks feel that their compliance programs are not as good as programs at larger banks. My response to these laments is to point out that the primary difference between a community bank compliance program and the compliance program at a larger bank is that the larger banks tend to make larger mistakes. There is a never
CFPB IS REVIEWING PREPAID CARDS
Category: CFPB, Regulation E
On May 23, 2012, the Consumer Financial Protection Bureau (CFPB) took the first step toward adopting consumer protections for the fast-growing prepaid card market. The Bureau’s Advance Notice of Proposed Rulemaking seeks input on how to ensure that consumers’ funds on prepaid cards are safe and that card terms and fees are transparent. The Bureau’s rulemaking will focus on “General Purpose Reloadable” prepaid cards which allow consumers to load the cards with money upfront and
In a recent case the FDIC claimed a bank violated ECOA and Regulation B by engaging in a pattern or practice of denying applications for a credit card based on an initial match of applicant names to the Office of Foreign Asset Control’s list of Specially Designated Nationals (“SDNs”) without further verification that the applicants were in fact SDNs, which resulted in a disparate impact upon Hispanic applicants. The bank agreed to pay a civil
CFPB RULES WILL SIMPLIFY/STRANGLE MORTGAGE POINTS AND FEES
Category: CFPB, Dodd-Frank Act, Financial Reform, Lending Compliance
On May 9, 2012 the Consumer Financial Protection Bureau (CFPB) outlined rules it is considering that would simplify (or strangle) mortgage points and fees. These rules, which the CFPB expects to propose this summer and finalize by January 2013, would make it easier for consumers to understand mortgage costs and compare loans so they can choose the best deal. The CFPB is considering proposals, required by the Dodd-Frank Wall Street Reform and Consumer Protection Act
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