Like kids in a sandbox the regulators cannot agree on the rules of the game being played. In this case the game is the Community Reinvestment Act. The implementing regulations and examinations procedures have been in serious need of revisions for 25 years. The agencies seem to agree that changes are needed, they just can’t agree on the direction of the change. Last year Comptroller of the Currency Otting jumped the gun and published an […]
Month: November 2019
CFPB PUBLISHES FALL 2019 UNIFIED AGENDA
Recently the Consumer Financial Protection Bureau (CFPB) published its Fall 2019 rulemaking agenda. The agenda identifies the regulatory matters that the CFPB reasonably anticipates having under consideration during the period from October 1, 2019 to September 30, 2020. The following summaries a few key topics: Proposed Fair Debt Collection Rule (Regulation F) – The CFPB proposed Regulation F in May 2019. Now the CFPB is testing consumer disclosures related to time-barred debt and, after testing, […]
FLOOD INSURANCE – ANOTHER LAST MINUTE REPRIEVE
Apparently another last minute approval by Congress and signature by the President has provided continued appropriations for the National Flood Insurance Program through December 20, 2019. In 30 days we play this silly game again.
FLOOD INSURANCE CONTINUATION – DOWN TO THE WIRE
On September 26, 2019 H.R 4378 provided continuation of funding for the National Flood Insurance Program (NFIP) through November 21, 2019. Now H.R. 3055, which among others items provides continuation of funding for NFIP, has passed in both the House and Senate. The House and Senate versions differed slightly and the differences are being resolved. Next the bill moves on for Presidential signature. The day is not over so Congress and the President have hours […]
CFPB COMMENCES TRID ASSESSMENT
On November 20 the Consumer Financial Protection Bureau (CFPB) announced that it commencing an assessment of its TRID (Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure) rules. The CFPB intends to address the TRID Rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors. The public is invited to comment on the feasibility and effectiveness of […]