When a big bank gets hit with a big penalty I often find that community banks think it is a “big bank thing” that does not impact community banks. Big banks make the same mistakes as community banks but they do it on a bigger scale. The recent settlement between the Consumer Financial Protection Bureau (CFPB) and USAA Federal Savings Bank (USAA) is a good case in point. The CFPB found that USAA: Violated the […]
Tag: CFPB
WHERE IS THE CFPB HEADED? UPDATE
Last week we reported that the CFPB has its first Director, not Acting Director, since Richard Cordray resigned a little over a year ago. We observed that due to lack of meaningful prior experience it is difficult to predict the direction in which Director Kathy Kraninger might steer the agency. She appears to be starting out with a few lightweight items. For example, under Director Cordray the agency was the Consumer Financial Protection Bureau. Acting […]
WHERE IS THE CFPB HEADED NOW?
On December 6, 2018 the Senate voted 50-49 to confirm Kathy Kraninger as the new Director of the Consumer Financial Protection Bureau (CFPB). She has no experience leading a government agency, no experience in financial institution regulatory matters, and no experience in consumer protection. So, there is no track record upon which to speculate about the direction of the agency with her holding the reins. Let’s enjoy the Holiday season, watch Director Kraninger’s first steps […]
TWO SMALL ENTITY COMPLIANCE GUIDES UPDATED FOR EGRRCPA
Last week the Bureau of Consumer financial Protection (BCFP) issued revised versions of the small entity compliance guides for the Loan Originator Rule and the Home Ownership and Equity Protection Act (HOEPA) Rule. Both Guides are updated for changes resulting from the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The Loan Originator Rule, among other requirements, addresses loan originator compensation, defines the concept of a loan originator and addresses qualification and other requirements related […]
BCFP PUTS BRAKES ON PAYDAY LOANS
On October 26, 2018 the Bureau of Consumer Financial Protection announced that it expects to issue proposed rules in January 2019 that will reconsider its rule regarding Payday, Vehicle Title, and Certain High-Cost Installment Loans and address the rule’s compliance date. The Bureau will make final decisions regarding the scope of the proposal closer to the issuance of the proposed rules. However, the Bureau is currently planning to propose revisiting only the ability-to-repay provisions and not the payments […]