The federal bank regulatory agencies have published an Interagency Statement of Pandemic Planning. The Federal Deposit Insurance Corporation (FDIC) released the statement with FIL-14-2020. The Office of the Comptroller of the Currency(OCC) released the statement with OCC Bulletin 2020-13. For further information on the topic see the recent Compliance Resource blog article on the topic
As the government fully gears up for testing for the Coronavirus, the number of reported cases will likely explode. That is when the panic will begin and the need for your Coronavirus Business Continuity Plan will be the greatest. The Federal Bank Regulatory agencies have not provided any recent guidance related to an appropriate response to a pandemic. Previous guidance from the agencies on this topic includes: Influenza Pandemic Preparedness: Interagency Advisory, OCC Bulletin 2006-12,
On February 28, 2020, the Department of Defense (DOD) published and made effective amendments to its interpretive rule related to the Military Lending Act (MLA). The MLA, which has undergone numerous revisions over the past several years, provides protection to servicemembers and their dependents by limiting the military annual percentage rate (MAPR) that a creditor may charge to a maximum of 36 percent and requiring disclosures among other consumer protections. Revisions to the MLA regulations
On February 26, 2020 the Consumer Financial Protection Bureau expanded its list of TRID Frequently Asked Questions to include 10 questions and answers related to Lender Credits. A copy, in Word format, of the FAQs is available, for no charge, at https://mycomplianceresource.com/product/trid-faqs-on-lender-credits-2/
FDCPA – PROPOSED REVISION TO THE PROPOSED REVISION
Category: CFPB, Fair Debt Collection Practices Act, Regulation F
On February 13, 2020 the Consumer Financial Protection Bureau (CFPB) published a supplemental notice of proposed rulemaking (NPRM) dealing with the Fair Debt Collection Practices Act and Regulation F. The NPRM supplements the May 2019 Proposed Rule by proposing to require debt collectors to make certain disclosures when collecting time-barred debts. The CFPB proposes to prohibit collectors from using non-litigation means (such as calls) to collect on time-barred debt unless collectors disclose to consumers during
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