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During October 2015 the Consumer Financial Protection Bureau (CFPB) published final rules to amend Regulation C. The rules are effective, for the most part, on January 1, 2018. On April 13, 2017 the CFPB published substantially proposed revisions to the final rules. Again on July 14, 2017 the CFPB published additional changes to the final rules. Today, with the clock racing to the January 1st mandatory compliance date the CFPB published final rules (225 pages) […]

We reported on July 7, 2013 that the Consumer Financial Protection Bureau (CFPB) had released significant revisions to the TRI Rules. Now the revisions have been published in the Federal Register. Amendments are effective 60 days after the date of publication in the Federal Register with a mandatory compliance date of October 1, 2018. So with today’s publication the revisions are effective on October 10, 2017. This will allow financial institutions, in short order, to […]

The CFPB has been busy with proposed changes in recent weeks.  Two proposed changes released by the CFPB will impact most financial institutions to some degree.  The CFPB released proposed changes to Regulation B on March 24, 2017.  The proposal is designed to permit creditors additional flexibility in complying with Regulation B – ECOA, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected.  In addition, the CFPB released changes […]

During a recent Regulation E training event, the class and I discussed the Regulation E Section 1005.11 “Procedures for resolving errors” and there, as always, was very active discussion of what a bank may request, but not require. I brought up the prohibition against requiring police reports as a requirement for the bank to either begin the investigation provision or to provide provisional credit and there were a number of questions.  Many banks have in […]

Last week the Consumer Financial Protection Bureau (CFPB) published a proposed amendment to Regulation P, which implements the Gramm-Leach-Bliley Act (GLBA) privacy provisions.  The amendment would implement a December 2015 statutory amendment to the GLBA providing an exception to this annual notice requirement for financial institutions that meet certain conditions. Final rules are expected shortly after the end of the 30-day comment period. A copy of the 41-page proposed rule is available at https://www.consumerfinance.gov/policy-compliance/rulemaking/rules-under-development/amendment-annual-privacy-notice-requirement-under-gramm-leach-bliley-act-regulation-p/