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 […]
Tag: CFPB
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 […]
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 […]