It appears that the Consumer Financial Protection Bureau (CFPB) will be busy during 2014, but a lot less busy than 2013. On December 3, 2014 the CFPB published a semi-annual update to its rulemaking agenda. The fall 2013 agenda reflects both continuing work on rulemakings mandated by the Dodd-Frank Act and significant issues in other markets for consumer financial products and services.
In the past year the CFPB issued rules to implement Dodd-Frank Act requirements and other reforms concerning mortgage originations, servicing, and most recently, the federal disclosures that consumers receive shortly after application and shortly before closing. In 2014 it appears likely that the CFPB will follow-up on several mortgage issues, such as how to apply certain exemptions under the Dodd-Frank Act that are designed to preserve credit in “rural or underserved” areas. We also expect a proposed rule to implement Dodd-Frank Act changes to the Home Mortgage Disclosure Act, which is designed to improve the mortgage data that is available to monitor the market and assess fair lending practices.
Action is also expected outside of the mortgage arena. Proposed rules for prepaid card products are likely.
The CFPB is also actively assessing the need for regulations in other markets for consumer financial products and services, particularly debt collection, payday loans and deposit advance products, and bank overdraft programs. We anticipate the CFPB to intensify work on these projects in 2014, for instance by testing consumer disclosures in connection with prepaid products and debt collection.
We also expect action from the CFPB to streamline and modernize regulations that they inherited from other agencies. A proposal regarding privacy notices is anticipated, possibly eliminating annual disclosures where a financial institution limits the sharing of information with third-parties and has not changed policies.
We hope that you, your family and the staff of your financial institution will be able to take some time out of your busy scheduled to enjoy the holiday season. We wish you a blessed holiday season and a healthy and prosperous new year.
