Archive

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., […]

OCC ISSUES CMP INFLATION ADJUSTMENTS FOR NATIONAL BANKS AND FEDERAL SAVINGS ASSOCIATIONS

The Office of the Comptroller of the Currency (OCC) has published a final rule announcing changes to the maximum amount of each civil money penalty (CMP), for national banks and Federal savings associations, to account for inflation pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990 as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The adjustments serve to maintain the deterrent effect of civil penalties and to […]