In a June 17, 2022 blog post, Rohit Chopra, Director of the Consumer Financial Protection Bureau (CFPB), declared, “Markets work best when rules are simple, easy to understand, and easy to enforce.” The CFPB is seeking to move away from highly complicated rules that have long been a staple of consumer financial regulation and towards simpler and clearer rules. In addition, the CFPB is dramatically increasing the amount of guidance it is providing to the […]
Category: CFPB
2021 HMDA DATA
On June 16, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on 2021 mortgage lending transactions reported under the Home Mortgage Disclosure Act (HMDA) by 4,338 U.S. financial institutions. Covered institutions include banks, savings associations, credit unions, and mortgage companies. The Snapshot National Loan-Level Dataset (Snapshot) released today contains the national HMDA datasets as of May 1, 2022. Key observations from the Snapshot include the following: For 2021, the number of reporting institutions […]
DON’T FORGET JUNETEENTH
On June 17, 2021, the President signed legislation that amended 5 U.S.C. 6103(a) to add “Juneteenth National Independence Day, June 19” (Juneteenth) to the list of Federal legal public holidays (Federal holidays). Various regulatory provisions cross-reference or otherwise refer to the Federal holidays listed in 5 U.S.C. 6103(a), including the Regulation Z definition of “business day.” In Regulation Z, “business day” is defined in § 1026.2(a)(6) generally to mean “a day on which the creditor’s […]
CFPB Circular – Adverse Action Based on Credit Models
On May 26, 2022, the Consumer Financial Protection Bureau (CFPB) confirmed that federal anti-discrimination law requires companies to explain to applicants the specific reasons for denying an application for credit or taking other adverse actions, even if the creditor is relying on credit models using complex algorithms. The CFPB published a Consumer Financial Protection Circular (Circular 2022-3) to remind the public, including those responsible for enforcing federal consumer financial protection law, of creditors’ adverse action notice […]
CFPB PUBLISHES SECOND SET OF PANDEMIC RESPONSE
On May 16, 2022, the Consumer Financial Protection Bureau (CFPB) published its second Mortgage Servicing COVID-19 Pandemic Response Metrics. The report provides the CFPB’s observations of data obtained from 16 large mortgage servicers to identify areas of risk in the servicers’ COVID-19 pandemic response. The report: Addresses key metrics for call center data, forbearance enrollments and exits, delinquency, and borrower profiles. Informs servicers’ own data reviews as they determine whether they are doing enough for […]