Archive

CFPB CRITICAL OF CREDIT BUREAU PROCEDURES

On November 4, 2021, the Consumer Financial Protection Bureau published a sixteen-page advisory opinion to highlight that a consumer reporting agency that uses inadequate matching procedures to match information to consumers, including name-only matching (i.e., matching information to the particular consumer who is the subject of a consumer report based solely on whether the consumer’s first and last names are identical or similar to the names associated with the information), in preparing consumer reports (for […]

AGENCIES INCREASE REGULATION M AND Z THRESHOLDS

On November 29, 2021 the Office of the Comptroller of the Currency, Treasury (OCC); Board of Governors of the Federal Reserve System (Board); and Bureau of Consumer Financial Protection (Bureau) announced new coverage thresholds for: Consumer Leasing (Regulation M) – Based on the annual percentage increase in the CPI-W as of June 1, 2021, the exemption threshold will increase from $58,300 to $61,000 effective January 1, 2022. Appraisal for Higher-Priced Mortgage Loans Exemption Threshold – […]

CFPB CONSIDERING HMDA REVISIONS

During the Trump administration the Trump CFPB shrunk the HMDA requirements. Now the Biden CFPB, “plans to review recent changes to the rule and evaluate their effectiveness. This evaluation will strengthen the CFPB’s ability to maintain a fair, competitive, and non-discriminatory mortgage market.” On November 16, 2021, the Consumer Financial Protection Bureau (CFPB) issued a Request for Information (RFI) to seek input on rules implementing the Home Mortgage Disclosure Act (HMDA). Specifically, the CFPB will […]

AS COVID RAGES ON, THE REGULATORS REENGAGE

On November 10, 2021, the Board of Governors of the Federal Reserve, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the state financial regulators (collectively, agencies) issued a joint statement to communicate to mortgage servicers the agencies’ supervisory and enforcement approach as risks associated with the Coronavirus Disease (COVID-19) pandemic continue to change. On April 3, 2020, the agencies […]

REGULATION Z THRESHOLDS PUBLISHED

On October 25, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z and its Official Interpretations. The final rule revises the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The CFPB is […]