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THE CFPB INHERITS REGULATIONS N and O

Congress enacted section 626 of the Omnibus Appropriations Act (Omnibus Appropriations Act) on March 11, 2009 and directed the Federal Trade Commission (FTC) to commence a rulemaking proceeding within 90 days of enactment with respect to mortgage loans. On May 22, 2009, the enactment of the Credit Card Accountability Responsibility and Disclosure Act clarified the FTC’s rulemaking authority under the Omnibus Appropriations Act to specify that the FTC’s rulemaking based on its authority pursuant to the Omnibus […]

THE CFPB INHERITS REGULATION M

The Consumer Leasing Act (CLA) was enacted in 1976 as an amendment to the Truth in Lending Act (TILA). The purpose of the CLA is to ensure meaningful and accurate disclosure of the terms of personal property leases for personal, family, or household use. The CLA and Regulation M require lessors to provide consumers with uniform cost and other disclosures about consumer lease transactions. The CLA has been implemented in Regulation M of the Board of […]

THE CFPB INHERITS REGULATIONS J, K, & L

The Interstate Land Sales Full Disclosure Act (ILSA) protects consumers by requiring certain land developers to register their plans and to provide prescribed disclosures to prospective purchasers. Developers of subdivisions with one hundred or more nonexempt lots, and developers of condominiums with one hundred or more nonexempt units, must register development plans with the Federal regulator designated by ILSA. These developers must also provide purchasers with a comprehensive disclosure statement known as a property report […]

THE CFPB INHERITS REGULATION I

The Federal Deposit Insurance Act (FDIA) established the Federal Deposit Insurance Corporation which must insure the deposits of banks and savings associations entitled to the benefits of insurance under the FDIA. Not all depository institutions are required to maintain Federal deposit insurance. The FDIA requires that depository institutions lacking Federal deposit insurance make certain insurance-related disclosures in periodic statements, account records, locations where deposits are normally received, and advertising.  The FDIA also requires such depository institutions […]

THE CFPB INHERITS REGULATIONS G & H

The Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act) provides for the licensing and/or registration of mortgage loan originators. The SAFE Act requires mortgage loan originators to register with the Nationwide Mortgage Licensing System and Registry, obtain a unique identifier, and maintain this registration. The SAFE Act further requires states to adopt minimum standards for licensing residential mortgage loan originators. The Federal registration requirements of the SAFE Act have been implemented […]