Archive

FDCPA – PROPOSED REVISION TO THE PROPOSED REVISION

On February 13, 2020 the Consumer Financial Protection Bureau (CFPB) published a supplemental notice of proposed rulemaking (NPRM) dealing with the Fair Debt Collection Practices Act and Regulation F. The NPRM supplements the May 2019 Proposed Rule by proposing to require debt collectors to make certain disclosures when collecting time-barred debts. The CFPB proposes to prohibit collectors from using non-litigation means (such as calls) to collect on time-barred debt unless collectors disclose to consumers during […]

TRID AND DAYLIGHT SAVING TIME

Daylight Saving Time (DT) begins on Sunday March 8, 2020 at 2:00 a.m. It ends on November 1, 2020 at 2:00 a.m. What does DT 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 […]

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 […]