Archive

Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements […]

We have had several recent questions on this topic. What constitutes an application for TRID is very different from the concept of “application” for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C. It would take a large book to thoroughly explore all the nuances of “applications” under federal laws. This article explores only a few basic concepts. Regulation Z Under Section 1026.2(a)(3)(ii), for transactions subject to […]

Can’t get excited about the CFPB’s fourth birthday? Well let’s celebrate the continued foot-dragging on the part of the CFPB and other Federal agencies. Section 1071 of the Dodd-Frank Act amended the Equal Credit Opportunity Act to require financial institutions to collect and report information concerning credit applications made by women- or minority-owned businesses and by small businesses. The law established an effective date of July 21, 2011. Since Section 1071 was scheduled to be […]

Earlier this week the Consumer Financial Protection Bureau (CFPB) published a article and issued a bulletin on the topic of Social Security disability income. In our November 10th  article on the same topic we warned you of the discrimination risk involved  in verifying this type of income. Now you can hear the same message from the CFPB. In the past, Social Security disability income recipients have faced special challenges in providing proof that their disability […]

Recently the City of Providence, Rhode Island filed a federal lawsuit alleging that Santander Bank, N.A. has discriminated against Providence’s minority communities by refusing to make prime mortgage loans available in minority neighborhoods as required under the Fair Housing Act. Providence is seeking millions in damages from Santander, Mayor Angel Taveras said, and hopes that federal regulators open investigations into potential redlining. Santander denied the allegations. Santander is owned by Spanish banking giant, Banco Santander […]