On June 9,2020 the Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, the Consumer Handbook on Adjustable Rate Mortgages booklet, also known as the CHARM booklet, required under the Real Estate Settlement Procedures Act (RESPA) implemented by Regulation X and the Truth in Lending Act (TILA) implemented by Regulation Z. New features include: A comparison table that describes adjustable rate mortgages and their differences in relation to fixed-rate loan products; […]
Tag: Consumer Financial Protection Bureau
ELECTRONIC CREDIT CARD DISCLOSURES AND COVID-19
On June 3, 2020 the Consumer Financial Protection Bureau (CFPB) issued a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. The Issue Where underlying law, such as Regulation Z, requires a written disclosure to a consumer, the Electronic Signatures in Global and National Commerce Act (E-Sign Act) allows the disclosure to be provided electronically subject to certain conditions, including consumers’ consent–commonly known as “E-Sign consent.” Some […]
CFPB FAQS FOR OPEN-END CREDIT AND COVID-19
On May 13 the Consumer Financial Protection Bureau (CFPB) published three Frequently Asked Questions (FAQs) regarding open-end (not home-secured) rules related to the COVID-19 pandemic. The FAQs are “compliance aids,” which do not have the weight of the law or the regulations. The first FAQ addresses changes to account terms. The answer indicates that a creditor may change terms on an open-end account, although most significant changes in terms require advance notice. It clarifies that […]
REGULATION B – CLARIFICATION FOR PPP LOANS
On May 6 the Consumer Financial Protection Bureau (CFPB) issued three clarifying Frequently Asked Questions ( FAQs) to support small businesses who have applied for a loan from their financial institution under the Small Business Administration’s (SBA) Paycheck Protection Program (PPP). Question 1. – Creditors are generally required under the Equal Credit Opportunity Act and Regulation B to notify applicants within 30 days of receiving a “completed application” of the creditor’s approval, counteroffer, denial or […]
STATUS OF PAYDAY RULE LITIGATION
A new joint status report was filed on Friday April 24, 2020 with the Texas federal district court hearing the lawsuit filed by two trade groups challenging the Consumer Financial Protection Bureau’s(CFPB) final Payday, Vehicle Title, and Certain High-Cost Installment Loans rule (Payday Rule). The report notes that the CFPB “is continuing to make progress” on its proposed rulemaking to rescind the Payday Rule’s ability-to-repay (ATR) provisions and references the CFPB’s statement in its Fall […]