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 […]
Tag: Regulation B
WHEN DO WE HAVE AN APPLICATION?
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 […]
VERIFYING SOCIAL SECURITY DISABILITY INCOME
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 […]
COLLECTING GOVERNMENT MONITORING INFORMATION
The Fourth Quarter 2013 issue of Consumer Compliance Outlook, published by the Board of Governors of the Federal Reserve Board, contains an excellent article which reviews and compares the rules for collecting Government Monitoring Information (GMI) under Regulations B (Equal Credit Opportunity Act) and Regulation C (Home Mortgage Disclosure Act). The article is available here.
MORE FINAL REVISED RULES – REGULATIONS B, X, AND Z
On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]