Archive

On January 16, 2018 the Consumer Financial Protection Bureau (CFPB) issued the following statement on the Payday Rule: “January 16, 2018 is the effective date of the Bureau of Consumer Financial Protection’s final rule entitled “Payday, Vehicle Title, and Certain High-Cost Installment Loans” (“Payday Rule”).  The Bureau intends to engage in a rulemaking process so that the Bureau may reconsider the Payday Rule. Although most provisions of the Payday Rule do not require compliance until August […]

The case of Leandra English v. Donald J. Trump concerns whether the President is authorized to name an acting Director of the Consumer Financial Protection Bureau (“CFPB”) or whether a CFPB employee appointed by the outgoing Director in the hours before he resigned is in charge. The CFPB was created by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The CFPB’s previous Director, Richard Cordray, resigned effective at midnight on Friday, November 24, 2017. […]

On November 9 the Consumer Financial Protection Bureau published additional 2018 lending compliance thresholds as follows: The HPML Appraisal Exemption Threshold contained in 1026.35(c)(2)(ii) increased from $25,500 to $26,000; and The Regulation Z Scope Thresholds contained in 1026.3(b)(1) increased from $54,600 to $55,800. The same threshold is applicable to Regulation M. Information regarding other TILA thresholds that were published in July is available at https://mycomplianceresource.com/annual-update-to-tila-dollar-amounts/ In a few weeks the remaining thresholds will be published. […]

Finally, HMDA covered financial institutions can view another piece to the never-ending puzzle of HMDA tools from the CFPB.  The HMDA Platform was released today for beta testing.  Starting with 2017 data collected, financial institutions are required to report HMDA data to the CFPB.  The platform must be utilized by all HMDA reportable financial institutions to submit their data required by March 1, 2018. The Bureau did clarify the reason for the release was to […]

On October 5, 2017 the Consumer Financial Protection Bureau (CFPB) made available a final new rule, 12 CFR Part 1041 (Regulation OO), for Payday, Vehicle Title and Certain High-Cost Installment Loans. The 1,690 page rule is, for the most part, effective 21months after publication in the Federal Register. The rule is complex and controversial. The development of the rule involved over five years of research, outreach, and a review of more than one million comments […]