The CFPB’s New Overdraft Fee Proposal
Category: CFPB, Overdrafts
On January 17, 2024, the CFPB proposed a 211-page rule to limit overdraft fees charged by the nation’s biggest financial institutions. The proposal is intended to close what the CFPB calls a loophole that exempts overdraft lending services from longstanding provisions of the Truth in Lending Act and other consumer financial protection laws. The CFPB stated that very large financial institutions have been issuing highly profitable overdraft loans, resulting in billions of dollars in revenue
The most common HMDA questions that we receive are about how to properly report multipurpose and multifamily properties. And it’s understandable… The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome new requirements. Here’s a breakdown of how to properly report multifamily and multipurpose properties for HMDA Let’s start with ‘multifamily”. The construction method and total units, together, replaced property type reporting
HMDA Enforcement Actions in 2023… The 2018 modifications to HMDA were massive and many financial institutions are still dealing with the challenges of collecting data under the burdensome requirements. These changes continue to prove to be cumbersome and taxing. Program failures continue to plague financial institutions and in 2023, there were three very large enforcement actions for failing to file accurate data. Additionally, due to a lawsuit the CFPB had to rescind the 100 loan
Last week FinCEN held it’s annual Law Enforcement Awards Program ,which recognizes cases that have been successfully prosecuted using reports provided financial institutions, and emphasized how BSA reporting really does make a difference. The stories are always interesting but I think they also serve as a reminder to our teams that the work they do is important and has a real impact. And for many, this might be a much-needed reminder. Often, there is no
Yesterday, FinCEN announced a filing deadline extension for Beneficial Ownership Information for companies created or registered in 2024. Beginning January 1, 2024, reporting companies will be required to file information with FinCEN regarding their beneficial ownership. The rule requires new reporting companies, that is those created after January 1, 2024, to file their initial report within 30 calendar days of “receiving actual or public notice that the creation or registration of the reporting company is
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