On May 26, 2022, the Consumer Financial Protection Bureau (CFPB) confirmed that federal anti-discrimination law requires companies to explain to applicants the specific reasons for denying an application for credit or taking other adverse actions, even if the creditor is relying on credit models using complex algorithms. The CFPB published a Consumer Financial Protection Circular (Circular 2022-3) to remind the public, including those responsible for enforcing federal consumer financial protection law, of creditors’ adverse action notice […]
Tag: CFPB
CFPB PUBLISHES SECOND SET OF PANDEMIC RESPONSE
On May 16, 2022, the Consumer Financial Protection Bureau (CFPB) published its second Mortgage Servicing COVID-19 Pandemic Response Metrics. The report provides the CFPB’s observations of data obtained from 16 large mortgage servicers to identify areas of risk in the servicers’ COVID-19 pandemic response. The report: Addresses key metrics for call center data, forbearance enrollments and exits, delinquency, and borrower profiles. Informs servicers’ own data reviews as they determine whether they are doing enough for […]
CFPB ISSUES ECOA ADVISORY OPINION
On May 9, 2022, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion to affirm that the Equal Credit Opportunity Act and Regulation B protect not only those actively seeking credit but also those who sought and have received credit. This is not a new position, it is a reaffirmation of long standing law and regulation. The advisory opinion is effective upon publication in the Federal Register, which is expected soon.
CFPB ISSUES SPANISH LANGUAGE FORMS AND A REMINDER
In late April, the Consumer Financial Protection Bureau (CFPB) issued: Eight Spanish language version of several adverse action sample disclosures; Six Spanish language version of several prepaid account sample disclosures; and A reminder of financial institutions’ obligation to serve the communities where they do business, including communities with limited English proficiency and also encouraged them to use the translations as they work with Spanish-speakers in their community.
CHOPRA’S PLANS
In April 26 testimony to Congress, CFPB Director Rohit Chopra outlined his plans for the Agency. Focusing Enforcement on Repeat Offenders and Other Major Market Actors When small businesses violate the law, federal enforcers are often quick to levy crippling sanctions. But when larger players repeatedly violate the law, agencies are far more lenient. During his tenure, the CFPB will not only focus on large actors engaged in widespread harm, but also enforce the law […]