The proposed regulation to implement section 1071 did not address the handling of joint applications. This writer and others commented on the lack of guidance for reporting joint applications. Joint applications for commercial and agricultural loans are not common, but they do occur. The issue is whether information is collected for each applicant, or for a single applicant, and if a single applicant, which applicant. The final regulation, published on March 30, includes comment 103(a)-10
Today the Consumer Financial Protection Bureau (CFPB) finalized the Section 1071, Business Data Collection rule required by Congress to increase transparency in small business lending, promote economic development, and combat unlawful discrimination. The rules require Lenders to collect and report information about the small business credit applications they receive, including geographic and demographic data, lending decisions, and the price of credit. The CFPB stated “the rule will work in concert with the Community Reinvestment Act,
CFPB’s Releases a Special Supervisory Highlights Report All About Junk Fees
Category: CFPB, Compliance Management, Fair Banking, Fair Lending, Fees, Junk Fees, Overdrafts, Risk Retention, UDAAP
Fee practices continue to be in the spotlight and with the release of the special addition of the CFPB’s Supervisory Highlight, it looks like they are about to get even more attention and scrutiny. The Highlights come within a few months of major enforcement actions and other CFPB guidance. Since the fall of 2022, three financial institutions have had the unfortunate experience of being cited and accused of having potentially unfair, deceptive, or abusive policies
CFPB UPDATES CONTACT INFORMATION
On March 20, 2023, the Consumer Financial Protection Bureau (CFPB) published a final rule to make non-substantive corrections and updates to CFPB and other Federal agency contact information found at certain locations in Regulations B, E, F, J, V, X, Z, and DD, including Federal agency contact information that must be provided with: The Equal Credit Opportunity Act adverse action notices; and The Fair Credit Reporting Act Summary of Consumer Rights. This final rule also revises the
LET THE ANALYSIS BEGIN
Category: FFIEC, HMDA, Regulation C
Modified Home Mortgage Disclosure Act (HMDA) data for 2022 submissions from 4,394 filers are now available on the Federal Financial Institutions Examination Council (FFIEC) website. A downloadable modified (to protect consumer privacy) LAR file is available for every financial institution that has completed a HMDA data submission for 2022. The data is typically used to: Verify the data you submitted a few weeks ago is properly presented. Compare your institution’s data to the data from
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