Archive

CFPB EXPANDS DISCRIMINATION PROTECTION TO DEPOSIT ACCOUNTS

On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced that is using Unfair, Deceptive and Abusive Acts and Practices (UDAAP) rules to prevent discrimination in all consumer finance markets including credit, servicing, collections, consumer reporting, payments, remittances, and deposits. Examiners will require supervised companies to show their processes for assessing risks and discriminatory outcomes, including documentation of customer demographics and the impact of products and fees on different demographic groups. The CFPB will […]

CFPB FOCUS ON RURAL AMERICA

On March 10, 2022, the Consumer Financial Protection Bureau (CFPB) reported a new initiative to focus on financial issues facing rural America. That effort will initially focus on rural banking deserts, discriminatory and predatory agricultural credit, and manufactured housing. Last month, Director Chopra invited over 50 people from organizations representing rural people across the country to tell their stories and share their concerns. Following are their stories. Rural Banking Deserts: Stakeholders described how stark declines in […]

CFPB FACTSHEET – APR CALCULATION FOR GENERAL QM

On February 23, 2022, the Consumer Financial Protection Bureau (CFPB) published Factsheet: Prepaid Interest and the General Qualified Mortgage APR Special Rule for Adjustable Rate Mortgages. Creditors that wish to make qualified mortgages (QMs) under the price-based General QM definition must calculate the annual percentage rate (APR) for loans to determine whether they satisfy the price-based General QM definition. The priced-based General QM definition contains a special rule for calculating the APR for loans where […]

CFPB 2022 HMDA REPORTABLE DATA CHART

The CFPB recently posted the Reportable HMDA Data: A Regulatory and Reporting Overview Reference Chart for HMDA Data Collected in 2022, a 38-page reference chart covering each of the data points required to be collected, recorded, and reported under Regulation C. The chart is a reference tool for data points required to be collected, recorded, and reported under Regulation C. Relevant regulation and commentary sections are provided for ease of reference. The chart also incorporates the […]

CONSIDERATION OF RELIGION IN A BUSINESS LOAN APPLICATION

On December 9, 2021, the CFPB issued a Supervisory Highlights report, which shines a light on legal violations identified by the CFPB’s examinations in the first half of 2021. A surprising item on the list was that CFPB examiners found that lenders improperly considered small business applicants’ religion in their credit decisions. For religious institutions applying for small business loans, some lenders improperly utilized a questionnaire that contained explicit inquiries about an applicant’s religion. Following […]