On November 16, 2012 the Consumer Financial Protection Bureau (CFPB) announced that it will give creditors extra time to provide certain new disclosures required under the Dodd-Frank Wall Street Reform and Consumer Protection Act in order to allow a more seamless integration with other mortgage disclosures that have been proposed by the Bureau. The Dodd-Frank Act: Requires the CFPB to integrate certain disclosures from the Truth in Lending Act (TILA) and the Real Estate Settlement […]
Tag: Consumer Financial Protection Bureau
PROPOSED RULE – CREDIT CARD ABILITY TO PAY
Today the Consumer Financial Protection Bureau (CFPB) announced that it is proposing to amend Regulation Z, which implements the Truth in Lending Act (TILA), and the official interpretation to the regulation, which interprets the requirements of Regulation Z. Regulation Z generally prohibits a card issuer from opening a credit card account for a consumer, or increasing the credit limit applicable to a credit card account, unless the card issuer considers the consumers ability to make […]
REMITTANCE RULES – SMALL BUSINESS GUIDE
On October 16th the Consumer Financial Protection Bureau (CFPB) published a small business compliance guide for the international electronic money transfers rule (also known as the remittance rule), which take effect on February 7, 2013. The guide is not a substitute for the rule, but it highlights issues that banks, in particular small banks and those that work with them, should consider while implementing the new requirements. Among other issues the guide addresses the exemption […]
DECEPTIVE MARKETING
We have seen a recent string of enforcement actions from the Consumer Financial Protection Bureau involving deceptive marketing practices. There are lessons for all banks to learn from these actions. What the Actions Had in Common The action was taken by the CFPB in coordination with another federal regulator (FDIC in one and OCC in the other). The action involved huge financial institutions. The action resulted in huge penalties. The actions involved deceptive acts in […]
MORE ON TESTING INTEGRATED MORTGAGE LOAN DISCLOSURES
Following our recent article about testing the integrated mortgage disclosure forms we received several inquiries requesting more information about the process, particularly about submitting a comment. This article responds to those requests. The Issue – The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Over 2,400 pages of proposed regulations have been published in just the past two months alone. A huge bank can assign a team to the task of […]