Archive

CFPB REGULATORY STATUS CHECK

On February 6, 2020 Kathleen Kraninger presented the Consumer Financial Protection Bureau’s (CFPB’s) Fall 2019 Semi-Annual Report to Congress, covering the period from .April 1, 2019, to September 30, 2019. The Report provides updates on a number of current regulatory efforts including, but not limited to: Payday, Vehicle Title, and Certain High-Cost Installment loans In February 2019, the CFPB released Notices of Proposed Rulemaking (NPRM) on the 2017 Payday, Vehicle Title, and Certain High-Cost Installment […]

CLARIFICATION OF ABUSIVE STANDARD

On January 21, 2020 the Consumer Financial Protection Bureau (CFPB) approved a policy statement that is intended to convey and foster greater certainty about the meaning of abusiveness. The statement provides a framework for the Bureau’s exercise of its supervisory and enforcement authority to address abusive acts or practices. providing a common-sense framework on how it intends to apply the “abusiveness” standard in supervision and enforcement matters. With the revised statement the CFPB: Intends to […]

CFPB PUBLISHES GUIDANCE ON GUIDANCE

On January 27, 2020 the Consumer Financial Protection Bureau (CFPB) published, in the Federal Register, a Policy Statement that announces a new designation for certain guidance, known as “Compliance Aids,” and to explain the legal status and role of guidance with that designation. Examples of compliance aids previously released by the CFPB include small entity compliance guides, instructional guides for disclosure forms, executive summaries, summaries of regulation changes, factsheets, flow charts, compliance checklists, frequently asked […]

TRID CONSTRUCTION LOAN GUIDES

On Wednesday, Dec. 18, 2019, the Consumer Financial Protection Bureau (CFPB) published two guides on disclosing construction-only and construction-permanent loans with examples based on common questions received by the Bureau. The Combined Guide  provides guidance for disclosing the phases together and the Separate Guide  provides guidance for disclosing the phases separately. Alternate Headline: CFPB Publishes Inadequate TRID Construction Loan Guidance More Than Four Years After the Effective Date Have you ever heard the old saying , “a day late […]