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 […]
Tag: Consumer Financial Protection Bureau
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 […]
HMDA FINAL RULE FOR EGRRCPA EXEMPTION
On August 31 the Bureau of Consumer Financial Protection issued a final rule to implement and clarify the requirements of section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), which amended certain provisions of the Home Mortgage Disclosure Act (HMDA). The rule clarifies: That insured depository institutions and insured credit unions covered by a partial exemption under the EGRRCPA have the option of reporting exempt data fields as long as they report […]
REGULATION Z – SELECTED 2019 THRESHOLDS
On August 27, 2018 the Consumer financial Protection Bureau (CFPB published a final rule amending Regulation Z. The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule revises, as applicable, 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 […]
PRIVACY PROVISIONS FINALLY FINALIZED
On August 10, 2018 the Bureau of Consumer Financial Protection (CFPB) completed the nearly three year process of issuing relatively minor amendments to implement legislation that allows financial institutions that meet certain requirements to be exempt from sending annual privacy notices to their customers. The Gramm-Leach-Bliley Act (GLBA) generally requires that financial institutions send annual privacy notices to customers. In December 2015, Congress amended the GLBA as part of the Fixing America’s Surface Transportation Act […]