Archive

On August 4, 2016 the Consumer Financial Protection Bureau (CFPB) published revisions to rules for servicers that went into effect on January 10, 2014. The CFPB issued proposed amendments to those rules in November 2014, and the final rule adopts many of the proposed provisions. This final rule clarifies, revises, or amends provisions regarding: Force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; Prompt crediting and periodic […]

As promised in the 2016 spring semi-annual agenda, the CFPB released today its proposal to end payday debt traps for consumers.  The proposed protections will cover those products that have developed a stigma of being harmful to consumers, including payday loans, auto-title loans, deposit advance products, and certain high-cost installment and open-end products.  While these may not be common products utilized in your financial institution, there may be a loan or two lurking on your […]

The CFPB recently released its spring 2016 semi-annual agenda.  There are many repeat items listed in this agenda that were also present in the fall 2015 agenda (see Jack’s December 10, 2015 blog article).  Those items repeated from the fall 2015 agenda appear to be either getting closer to final regulatory release or are being pushed further down the priority list.  Some of the items mentioned in the agenda that we may see action on […]

Last fall, we published a blog article that reviewed the intricacies of the “Liability after Foreclosure” disclosure.  Here we provide a quick update and add some valuable new information. As a refresher, the following disclosure appears in the Loan Estimate but only when the transaction is defined as a refinance: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses […]

“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, […]