Archive

SPECULATION ENDS – FDCPA AND UDAP CROSS PATHS

Massive revisions to the Fair Debt Collection Practices Act (FDCPA), and its implementing Regulation F, have been unfolding over the past few years. The final rule is effective on November 30, 2021, although the CFPB has proposed to extend the effective date to January 29, 2022. Many banks want to operate under the assumption that the FDCPA and Regulation F do not apply to their operations. We have steadfastly maintained that the law and regulation […]

CFPB INTERIM FINAL RULE REGARDING EVICTION MORATORIUM

Nearly 9 million households are behind on their rental payments. Tens of thousands of renters are being evicted every week, often without being told of their rights under the CDC moratorium. As the CDC has found, tenants who are evicted may end up homeless or in crowded or shared living settings, increasing their vulnerability to COVID-19 and the risk of the disease spreading throughout communities. Such evictions can have long-term health, financial, and social consequences […]

ACTING CFPB DIRECTOR SETS PRIORITIES AND EXPLORES PRESERVING QM STATUS QUO

As expected, and as we discussed in our recent “Compliance Expectations for the New Administration” webinar, the Biden administration is effecting changes in financial oversight that will impact financial institutions. One of those changes included, at the request of President Biden, was the resignation of CFPB Director Kathy Kraninger and the appointment of Dave Uejio as Acting Director of the CFPB; Acting Director Uejio will serve until President Biden’s nominee for CFPB Director, Rohit Chopra, […]