On January 13, 2021, the Consumer Financial Protection Bureau (CFPB) published a “Statement Regarding the Provision of Financial Products and Services to Consumers with Limited English Proficiency.” The Statement provides principles and guidelines to assist financial institutions in decision making concerning how best to serve Limited English Proficiency (LEP) consumers and to facilitate compliance with ECOA and UDAAP laws. This is the latest in a series of regulatory releases that provide “hints” at appropriate action. […]
Tag: CFPB
Biden Regulatory Freeze
On January 20, President Biden’s Chief of Staff Ronald Klain issued memorandum to the heads of executive departments and agencies setting forth the terms of a regulatory freeze. Summary The memorandum requires the following subject to limited exceptions: No rules can be issued or proposed until a department or agency head appointed by President Biden has reviewed and approved the rule. A rule that has been sent to the Federal Register but not yet published must be immediately […]
CFPB Advisory Opinion on Special Purpose Credit Program
On December 21, 2020, the Consumer Financial Protection Bureau published an Advisory Opinion (AO) on Special Purpose Credit Programs established per the requirements of the Equal Credit Opportunity Act and Regulation B. It is designed to address regulatory uncertainty in special purpose credit programs designed and implemented by for-profit organizations to meet special social needs. Specifically, this AO clarifies: The content that a for-profit organization must include in a written plan that establishes and administers […]
Final Final Fair Debt Collections Practices Act is Published
On December 18, 2020, the Consumer Financial Protection Bureau (CFPB) released the second part of its final rule, Regulation F, which implements the Fair Debt Collection Practices Act. The first part of the final rule was published on October 30, 2020. The most recent release has three primary components dealing with validation notices, passive debt collection through negative reporting, and the collection of time-barred debt. Most notably, the provisions dealing with time-barred debt depart significantly […]
CFPB ISSUES TWO QM RULES
On December 10, 2020, the Consumer Financial Protection Bureau (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Rule, replaces the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43 percent with a limit based on the loan’s pricing. The second final rule, reveals a new Seasoned QM. General QM – Under the final rule a loan receives a conclusive […]