CFPB Rescinds its 2020 HMDA Threshold Ruling

Yesterday, the CFPB issued a Notice rescinding its 2020, Home Mortgage Disclosure Act (HMDA) Final Rule changing the loan volume reporting threshold for closed-end mortgage loans.  This comes on the heels of a ruling by the United States District Court for the District of Columbia, in September of this year.  The ruling stated the CFPB did not have the authority to change the original reporting threshold from 25 to 100. The April 2020, the CFPB’s […]


On November 16, 2022, the Consumer Financial Protection Bureau (CFPB) released the Fall 2022 Supervisory Highlights report on legal violations identified during the CFPB’s supervisory examinations in the first half of 2022. The key findings of the Report are elaborated upon below. Inaccurate Credit Reports CFPB examiners found that one or more of the nationwide consumer reporting companies failed to report to the CFPB the outcome of their reviews of complaints about inaccuracies on consumers’ […]


In Community Financial Services Association v. CFPB, which has been working its way through the courts since 2018, a three-judge panel of the 5th U.S. Circuit Court of Appeals (Louisiana, Mississippi, and Texas) threw out a CFPB regulation governing high-interest-rate lenders and ruled that the way the bureau is funded, is unconstitutional. The immediate impact is that the Payday Lending Rule is suspended in Louisiana, Mississippi, and Texas. The CFPB is expected to appeal to the […]


Daylight Saving Time (DST) ends on November 6, 2022 at 2:00 a.m. What does DST have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DST need to remember to change the […]

1071 Preparation: What Should We Do Now?

  In the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) of 2010, Congress directed the Consumer Financial Protection Bureau (CFPB) to adopt regulations that will govern data collection for small business and agricultural lending. Section 1071 of Dodd-Frank amended the Equal Credit Opportunity Act (ECOA, Reg. B) to require financial institutions to collect and submit specific data to the CFPB. Congress enacted section 1071 for the purpose of: Facilitating enforcement of fair lending laws. […]