On October 25, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z and its Official Interpretations. The final rule revises the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The CFPB is […]
Month: October 2021
REVISED REGULATION Z EXAMINATION PROCEDURES
On October 25, 2021, the Board of Governors of the Federal Reserve System issued Consumer Affairs Letter (CA 21-14) announcing revised Interagency Examination Procedures for Regulation Z. The comprehensive procedures are 384 pages in length. The revised procedures reflect amendments to Regulation Z published by the Consumer Financial Protection Bureau in 2020 and 2021: Implementing permanent changes to Regulation Z’s qualified mortgage provisions, and Implementing an extension and phase-out for the GSE Patch, which had […]
OCC FAQS ON RESCINDED FINAL CRA RULE
On October 26, the Office of the Comptroller of the Currency (OCC) took the unusual step of issuing frequently asked questions (Bulletin 2021-50) about a notice of proposed rulemaking (NPRM) soliciting comments on the proposal to rescind the OCC’s Community Reinvestment Act (CRA) rule issued on June 5, 2020. The NPRM, which was published in the Federal Register on September 17, 2021, proposes that the June 2020 CRA rule largely be replaced with the rules adopted jointly by the […]
REDLINING IS ERUPTING
On October 22, 2021 redlining hell broke loose. Trustmark – The Consumer Financial Protection Bureau (CFPB) and U.S. Department of Justice (DOJ), in cooperation with the Office of the Comptroller of the Currency (OCC), took action today to put an end to alleged redlining by Trustmark National Bank. The CFPB and DOJ allege that Trustmark discriminated against Black and Hispanic neighborhoods by deliberately not marketing, offering, or originating home loans to consumers in majority-Black and […]
CFPB KICKS ENFORCEMENT INTO HIGH GEAR
The Consumer Financial Protection Bureau (CFPB) will name Eric Halperin, a longtime consumer advocacy attorney and former official with the U.S. Department of Justice during the Barack Obama administration, to serve as its new enforcement director. This is according to original reporting at Bloomberg Law, based on conversations with internal CFPB sources who wished to remain unnamed. It is expected that Halperin will be appointed by CFPB Director Rohit Chopra in the coming days, according […]