“For the rest of this year and the next, our rulemaking agenda at the Consumer Bureau will remain quite active.” Director Richard Cordray recently stated. So what can we expect to see from the CFPB? The agency is working on new or revised rules for: Overdraft fees, including the opt-in process for overdraft coverage of electronic transactions; Collection and publication of data on small business lending (The Dodd-Frank Act required final rules by July 21, […]

The FACT Act’s Risk-Based Pricing Rules (Part 1 – The Big Picture)

Effective January 1, 2011 section 311 of the FACT Act requires a risk-based pricing notice. The notice is required when a person both: (1) Uses a consumer report in connection with an application for, or a grant, extension, or other provision of, credit to that consumer that is primarily for personal, family, or household purposes; and (2) Based in whole or in part on the consumer report, grants, extends, or otherwise provides credit to that […]