Archive

CFPB – PROPOSED RULE REGARDING REMITTANCE TRANSFERS

Recently the Consumer Financial Protection Bureau (CFPB) published a proposed revision to Regulation E regarding remittance transfers. The proposal addresses three narrow issues. Additional flexibility regarding the disclosure of foreign taxes and fees If a remittance transfer provider does not have specific knowledge regarding variables that affect the amount of foreign taxes imposed on the transfer the proposal would: Continue to permit a provider to rely on a sender’s representations regarding these variables. Separately permit […]

REVISED INTERAGENCY EXAMINATION PROCEDURES FOR REGULATION Z

Several sources recently reported that the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council approved revised interagency examination procedures for Regulation Z – Truth in Lending. So, is this a significant event? Does your bank need to do anything in response? The primary revisions to the examination procedures result from the July 21, 2011 transfer of Regulation Z from the Federal Reserve Board to the Consumer Financial Protection Board.  To minimize […]

DELAYED REMITTANCE RULE

On November 27, 2012 the Consumer Financial Protection Bureau (CFPB) announced that it is delaying the effective date of the final Regulation E Remittance Rules from February to May of 2013 to accommodate a few last minute changes. The CFPB plans to propose a narrow set of changes to address the rule’s provisions on: (1) errors resulting from incorrect account numbers provided by senders of remittance transfers; (2) the disclosure of certain foreign taxes and […]

RAJ DATE RESIGNS

Recently it was announced that Raj Date, the second highest ranking official at the Consumer Financial Protection Bureau (CFPB), plans to resign from the agency he helped create. Date is departing the CFPB on or around January 31, 2013 after the agency finalizes the slate of mortgage rules mandated by the Dodd-Frank Act. Mr. Date has had a long and varied career in and around U.S. financial institutions – as a strategy consultant, as a […]

2013 THRESHOLDS

On November 20, 2013 the Consumer Financial Protection Bureau published notices increasing several thresholds for 2013.  Two notices increased the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. The Dodd-Frank Act amendment the Truth in Lending Act and the Consumer Leasing Act to adjust these thresholds annually by the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical […]