Archive

CFPB PROPOSAL ON CREDIT CARD FEES

On February 1, 2023, the Consumer Financial Protection Bureau (CFPB) proposed a rule to curb excessive credit card late fees that cost American families about $12 billion each year. Major credit card issuers continue to profit off late fees that are protected by an expansive immunity provision. Credit card companies have also relied on this provision to hike fees with inflation, even if they face no additional collection costs. The proposed rule would help ensure […]

FEDERAL BANK REGULATORY AGENCIES CONTINUE TO IGNORE SEXUAL ORIENTATION AND GENDER IDENTITY ISSUES

On June 15, 2020, the United States Supreme Court in the case of Bostock v Clayton County declared that disparate treatment based on sexual orientation or gender identity is sex discrimination under federal law. It is the law of the land. On March 9, 2021, the Consumer Financial Protection Bureau (CFPB) issued an interpretative rule to amend Regulation B to clarify that disparate treatment based on sexual orientation or gender identity is sex discrimination under […]

CFPB’S FALL 2022 SEMI-ANNUAL AGENDA

The Consumer Financial Protection Bureau’s (CFPB) Fall 2022 Semi-Annual Agenda includes10 items – one in the final rule stage, five in the proposed rule category, and four items in the prerule stage. Final Rule Stage – The final rule item is the Small Business Lending Data Collection under the Equal Credit Opportunity Act. The CFPB’s next action for the section 1071 rulemaking is the issuance of a final rule, which is expected in January 2023. […]

FINAL THRESHOLD UPDATE FOR 2022

I bet you thought that you were all wrapped up on your compliance news for 2022, huh? Well…not so fast! On December 28, 2022, The CFPB released the final HMDA threshold and the remaining Regulation Z thresholds. The HMDA threshold was increased from $50 million in 2022 to $54 million in 2023. The HPML Small Creditor Threshold was increased from $2.336 billion to $2.537 billion in 2023. The HPML Intermediate Creditor Threshold was increased from […]

HAPPY HOLIDAYS AND A THRESHOLD UPDATE

We hope you enjoyed Christmas or the holiday you enjoy with your family. And, we hope the New Year holds great promise for you all. Annual Thresholds On December 22, 2022, we published a blog article entitled Final Regulation Z Thresholds. We had an error when loading the article to our website. The Qualified Mortgage thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) were misstated. The corrected […]