Archive

THE BCFP’S SANDBOX

On September 10, 2018 the Bureau of Consumer Financial Protection (BCFP) proposed to create a Disclosure Sandbox through its revised Policy to Encourage Trial Disclosure Programs (Policy or TDP Policy), which is intended to carry out the BCFP’s authority under Section 1032(e) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). Comments will be received until October 10, 2018. The BCFP believes that there may be significant opportunities to enhance […]

HMDA FINAL RULE FOR EGRRCPA EXEMPTION

On August 31 the Bureau of Consumer Financial Protection issued a final rule to implement and clarify the requirements of section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), which amended certain provisions of the Home Mortgage Disclosure Act (HMDA). The rule clarifies: That insured depository institutions and insured credit unions covered by a partial exemption under the EGRRCPA have the option of reporting exempt data fields as long as they report […]

ZILLOW?

Recently a member of our Compliance Masters Group inquired, “It looks like the CFPB has dropped their case with Zillow according to a statement by Zillow.  We had a lot of our lenders wanting to co-market with realtors on Zillow.  Now what?” Good question. What we do know – Zillow Group received a letter from the CFPB on June 22 stating that the CFPB “had completed its investigation, that it did not intend to take […]

STATUS OF THE EGRRCPA HMDA AMENDMENTS

On July 5, 2018 both the Office of the Comptroller of the Currency (OCC Bulletin 2018-19) and the Consumer Financial Protection Bureau issued statements regarding the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA) amendments to the Home Mortgage Disclosure Act (HMDA). The President signed the EGRRCPA on May 24, 2018. Section 104 of the law amends HMDA. The EGRRCPA provides exemptions from certain HMDA requirements for insured depository institutions, with satisfactory or outstanding […]

CFPB PUBLISHES SPRING 2018 AGENDA

On May 10, 2018 the Consumer Financial Protection Bureau (CFPB) published its semi-annual regulatory agenda. The agenda includes rulemaking actions in pre-rule, proposed rule, final rule, long-term, inactive, and completed stages. Priorities are clearly changing. The agency’s Acting Director has decided to reclassify as “inactive” certain rulemakings that had been listed in previous editions of the agenda in the expectation that final decisions on whether and when to proceed with such projects will be made […]