Archive

CFPB Rescinds its 2020 HMDA Threshold Ruling

Yesterday, the CFPB issued a Notice rescinding its 2020, Home Mortgage Disclosure Act (HMDA) Final Rule changing the loan volume reporting threshold for closed-end mortgage loans.  This comes on the heels of a ruling by the United States District Court for the District of Columbia, in September of this year.  The ruling stated the CFPB did not have the authority to change the original reporting threshold from 25 to 100. The April 2020, the CFPB’s […]

FALL 2022 CFPB SUPERVISORY HIGHLIGHTS

On November 16, 2022, the Consumer Financial Protection Bureau (CFPB) released the Fall 2022 Supervisory Highlights report on legal violations identified during the CFPB’s supervisory examinations in the first half of 2022. The key findings of the Report are elaborated upon below. Inaccurate Credit Reports CFPB examiners found that one or more of the nationwide consumer reporting companies failed to report to the CFPB the outcome of their reviews of complaints about inaccuracies on consumers’ […]

CFPB’s Guidance on Junk Fees

Fee income practices have been making headlines for months, and in some cases years. Financial institutions that have had the unfortunate experience of being cited or accused of having potentially unfair, deceptive, or abusive policies can attest to the damage certain unchecked fee income practices can have on the organization.  Reputation, income, and company morale are all negatively affected when fee income policies are determined to be unfair or deceptive. We here at COMPLIANCE RESOURCE […]

5TH CIRCUIT CHALLENGES THE CFPB’S RIGHT TO EXIST

In Community Financial Services Association v. CFPB, which has been working its way through the courts since 2018, a three-judge panel of the 5th U.S. Circuit Court of Appeals (Louisiana, Mississippi, and Texas) threw out a CFPB regulation governing high-interest-rate lenders and ruled that the way the bureau is funded, is unconstitutional. The immediate impact is that the Payday Lending Rule is suspended in Louisiana, Mississippi, and Texas. The CFPB is expected to appeal to the […]

DAYLIGHT SAVING TIME TRID REMINDER

Daylight Saving Time (DST) ends on November 6, 2022 at 2:00 a.m. What does DST have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DST need to remember to change the […]