On January 24, 2020 the Consumer Financial Protection Bureau (CFPB) approved a Policy Statement that was intended to clarify the meaning of “abusive” in Unfair, Deceptive, or Abusive Acts or Practices. Compliance Resource informed you of this in our blog early last year. The statement provided a framework for the CFPB’s exercise of its supervisory and enforcement authority to address abusive acts or practices in an effort to provide a common-sense framework on how the […]
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ACTING CFPB DIRECTOR SETS PRIORITIES AND EXPLORES PRESERVING QM STATUS QUO
As expected, and as we discussed in our recent “Compliance Expectations for the New Administration” webinar, the Biden administration is effecting changes in financial oversight that will impact financial institutions. One of those changes included, at the request of President Biden, was the resignation of CFPB Director Kathy Kraninger and the appointment of Dave Uejio as Acting Director of the CFPB; Acting Director Uejio will serve until President Biden’s nominee for CFPB Director, Rohit Chopra, […]
AGENCIES ADJUST CMPs FOR INFLATION
The FDIC, FRB, NCUA, CFPB and FinCEN have each announced adjustments to the maximum amount of civil money penalties (CMP), for which they have assessment authority, to account for inflation. The adjustments serve to maintain the deterrent effect of civil penalties and to promote compliance with the law. Compliance Resource previously reported of the OCC’s final rule announcing changes to the maximum amount of each civil money penalty for national banks and Federal savings associations […]
Misguided Efforts to Limit Loan Rates
On January 13, 2021, the Illinois legislature passed SB 1792, that, among other things, overhauls the state’s consumer finance laws through the provisions of the “Predatory Loan Prevention Ac.t” SB 1792 would extend the 36% “all-in” Military Annual Percentage Rate (MAPR) finance charge cap of the federal Military Lending Act (MLA) to “any person or entity that offers or makes a loan to a consumer in Illinois” unless made by a statutorily exempt entity (i.e., […]
Happy New Year!
Rest up and get ready to enjoy what will be a very busy compliance new year.