On July 7, the Consumer Financial Protection Bureau (CFPB) published a legal interpretation to ensure that companies that use and share credit reports and background reports have a permissible purpose under the Fair Credit Reporting Act (FCRA). The CFPB’s new advisory opinion makes clear that credit reporting companies and users of credit reports have specific obligations to protect the public’s data privacy. The advisory also reminds covered entities of potential criminal liability for certain misconduct.
FFIEC UPDATES LIST OF DISTRESSED OR UNDERSERVED GEOGRAPHIES
Category: CRA, FDIC, Federal Reserve Board, FFIEC, OCC
On July 1, 2022 the Federal Reserve Board, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency announced the availability of the 2022 list of distressed or underserved nonmetropolitan middle-income geographies. These are geographic areas where revitalization or stabilization activities are eligible to receive Community Reinvestment Act (CRA) consideration pursuant to the definition of community development under the agencies’ regulations. Revitalization or stabilization activities in these geographies are eligible to
CFPB TARGETS DEBT COLLECTOR CONVENIENCE FEES
Category: CFPB, Fair Debt Collection Practices Act, Regulation F
On June 29, the CFPB issued an advisory opinion affirming that federal law prohibits debt collectors from charging “pay-to-pay” fees. These charges, commonly described by debt collectors as “convenience fees,” are imposed on consumers who want to make a payment in a particular way, such as online or by phone. The advisory opinion is based on language in Section 808 of the Fair Debt Collection Practices Act (FDCPA), which prohibits debt collectors from collecting any
SMALL BUSINESS LENDING RULE DELAYED
Category: CFPB, CRA, ECOA, Regulation B
On June 27, 2022, the Office of Management and Budget published the Spring 2022 Unified Agenda of Federal Regulatory and Deregulatory Actions. The Agenda breaks down rules from over 60 federal departments, agencies, and commissions. In the list of actions from the Consumer Financial Protection Bureau (CFPB) is an announcement that the final rule for Small Business Lending Data Collection Under the Equal Credit Opportunity Act is not expected until March 2023. The rule will
Day 3 – ABA RCC
Category: ABA RCC
Another day of too much to choose from and deciding where to go. It has been a challenge to pick classes lots of good topics to choose from this year. Focus today seemed to be on the compliance officer and compliance teams in general. Couple of key takeaways from today: Communication There can never be too much outreach and communicating often is necessary. However, communicating with a purpose and the right medium is important. What
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