On October 3, 2016 the CFPB issued its final rule for general purpose prepaid accounts which will generally go into effect on October 1, 2017. This culminated a 4+ year wait since the CFPB announced its initial intention to regulate prepaid accounts and 2 years from its proposal. The CFPB’s initial 870 page ANPR has morphed into a 1,689-page final rule so it’s easy to determine that numerous products and requirements were added on that […]
Category: Regulation Z
FINAL REVISIONS TO SERVICING RULES
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 […]
TRID PROPOSAL
“The Consumer Financial Protection Bureau has begun drafting a Notice of Proposed Rulemaking (NPRM) to make adjustments to the Know Before You Owe rule,” CFPB director Richard Cordray told industry trade groups in an April 28 letter. Cordray said he hopes the NPRM will be issued in late July. Well his “hopes” became reality late last week. On July 28 the CFPB Published a 293-page proposal. The proposal has a quick 82-day comment period, which […]
STILL TRID-ING WATER IN SAN DIEGO
Greetings from the Manchester Grand Hyatt in sunny San Diego, CA! The locals say we are in the middle of the “June Gloom” with some hazy weather but there is plenty of energy at the ABA regulatory compliance gathering. Hundreds in the banking compliance community have come together to share knowledge and make connections with other like-minded professionals. As always, the ABA puts on a premier event with offerings in subjects across the entire spectrum […]
CFPB SEMI-ANNUAL AGENDA
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 […]