CFPB Monitor

APRIL 20, 2022

The CFPB has filed a new lawsuit against TransUnion, two of its subsidiaries (TransUnion Interactive, Inc. TUI) and TransUnion, LLC (TULLC)), and a former TUI executive alleging that the defendants violated the CFPB’s 2017 consent order with the corporate defendants. In addition to requiring payment of $13.9

Compliance 78

Compliance Leadership Report Regulation 78

CFPB Monitor

AUGUST 9, 2021

The CFPB and the two trade groups challenging the CFPB’s 2017 final payday/auto title/high-rate installment loan rule (2017 Rule) have filed briefs with the Texas federal court regarding a compliance date for the 2017 Rule’s payment provisions. the unconstitutional removal provision) vanished when the U.S.

Compliance 78

Compliance Groups Payments Texas 78

PYMNTS

DECEMBER 3, 2019

3), the Consumer Financial Protection Bureau (CFPB) has proposed to boost the number of smaller banks and credit unions (CUs) that would not be governed by rules tied to international money transfers. The average amount sent by MSBs on behalf of consumers was $381, reported the CFPB. As Bloomberg Law reported Tuesday (Dec.

Compliance 131

Compliance United States Analysis National 131

CFPB Monitor

NOVEMBER 18, 2021

Earlier this week, the CFPB issued a Request for Information (RFI) regarding an assessment of the significant amendments to the Home Mortgage Disclosure Act rules, known as Regulation C, adopted in October 2015 and subsequently revised in several additional rulemakings (the “HMDA Rule”).

Compliance 78

Compliance Data Lending Operations 78

CFPB Monitor

OCTOBER 31, 2022

The CFPB has taken a significant step towards issuing regulations to implement Section 1033 of the Dodd-Frank Act by releasing an outline of the proposals it is considering in preparation for convening a small business review panel (Panel). Types and scope of information a covered data provider must make available.

Data 78

Data Compliance Regulation Policies 78

Abrigo

MAY 19, 2023

Takeaway 3 Consider what your financial institution can do to give junior loan reviewers experience in various aspects of banking to relieve senior staff. WATCH Takeaway 1 Loan review departments often lack funds for training and education, but a shortage of experienced loan reviewers is a challenge for many banks.

Training 195

Training Lending Risk Management Guidelines 195

CFPB Monitor

MARCH 4, 2021

The CFPB has proposed to delay the mandatory compliance date for the new general qualified mortgage (QM) rule that amends the Regulation Z ability to repay/QM rule from July 1, 2021 to October 1, 2022. Is considering whether to initiate a rulemaking to revisit the seasoned loan QM rule.

Compliance 78

Compliance Policies Community Regulation 78

CFPB Monitor

OCTOBER 4, 2022

Last week, the CFPB issued a “ Student Loan Servicing Special Edition ” of Supervisory Highlights. In this blog post, we highlight a stealth expansion of supervisory jurisdiction and focus on the CFPB’s findings in two key areas: Transcript withholding policies at institutional lenders (e.g. Supervisory jurisdiction.

Policies 146

Policies Compliance Payments Training 146

CFPB Monitor

OCTOBER 8, 2020

The CFPB has issued a “ Statement of Policy on Applications for Early Termination of Consent Orders.” Must not be within the first year after entry of the consent order and must have fully implemented all compliance and redress plans required under the consent order at least six months before applying. Compliance with consent order.

Policies 78

Policies Compliance System Meeting 78

CFPB Monitor

FEBRUARY 25, 2021

In a related blog post , Acting Director Uejio notes that because of the economic hardship and uncertainty caused by the COVID-19 pandemic, the CFPB must do all it can to protect homeowners and promote stability in the housing market.

Compliance 78

Compliance Policies Regulation Marketing 78

CFPB Monitor

JUNE 7, 2022

On May 25, 2022, my colleagues, Mike Gordon, John Culhane and Ron Vaske published a blog which reported on a press release issued by the CFPB on the prior day entitled “CFPB Launches New Effort to Promote Competition and Innovation in Consumer Finance.” Cisneros of the CFPB’s press office. Not so, according to Raul E.

Innovation 78

Innovation Compliance Conference Operations 78

CFPB Monitor

FEBRUARY 28, 2022

The CFPB recently issued an outline entitled Small Business Advisory Review Panel for Automated Valuation Model (AVM) Rulemaking. In announcing the outline, the CFPB stated that overvaluing homes can put family wealth at-risk, create reselling challenges, and lead to higher rates of foreclosure.

Lending 78

Lending Policies System Compliance 78

CFPB Monitor

AUGUST 23, 2022

The CFPB has supervisory authority for compliance with Federal consumer financial laws (which includes the Dodd-Frank UDAAP prohibition) over all banks and thrifts with $10 billion or more in total assets. The FDIC discusses the following three categories of risk: Consumer compliance risk. Potential risks. Litigation risk.

FDIC 78

FDIC Compliance System Regulation 78

CFPB Monitor

JULY 5, 2022

The CFPB has issued an order terminating the approval order issued in December 2020 to Payactiv, Inc. through the CFPB’s Compliance Assistance Sandbox (CAS) Policy. In January 2022 , Seth Frotman, now CFPB General Counsel, indicated that more clarity on EWA products was needed from the CFPB.

Regulation 78

Regulation Policies Innovation Analysis 78

CFPB Monitor

OCTOBER 19, 2022

The court explained: The CFPB provides a model form along with Regulation F. The phrase ‘safe harbor’ indicates that use of the form is sufficient but not necessary for compliance. See CFPB, Regulation F Final Rule , 12 C.F.R. See CFPB, Regulation F Final Rule , Section-by-Section Analysis at pg. See id. § 1006.34(d)(2).

Regulation 78

Regulation Compliance Analysis Exercises 78

CFPB Monitor

JUNE 10, 2022

The Consumer Financial Protection Bureau (CFPB) recently highlighted its concerns regarding the use of military allotments for loan repayment, inviting servicemembers who believe they have been treated unfairly by companies seeking repayment through the military allotment system to file complaints with them so that they can investigate further. .

System 78

System Lending Payments Compliance 78

CFPB Monitor

DECEMBER 29, 2020

With respect to judgments RAB obtained without the proper license, the consent order requires RAB to: (1) suspend current and future collection activities; (2) vacate those judgments; and (3) notify consumers with payment agreements that the debts have been satisfied.

New Jersey 137

New Jersey Rhode Island Connecticut Compliance 137

Abrigo

JUNE 2, 2021

Takeaway 3 BSA exam plans should include a review of the common themes and hot topics showing up in recent examination criticisms. Does it address a “culture of compliance”? Culture of compliance. This includes compliance from top, to middle, to frontline leadership. Review Regulatory Material. Calibration.

How To 195

How To Training Compliance Policies 195

CFPB Monitor

APRIL 12, 2021

On April 1, 2021, the CFPB issued Compliance Bulletin 2021-02 (the “Bulletin”), warning mortgage servicers to “take all necessary steps now to prevent a wave of avoidable foreclosures this fall.” The Bulletin further provides that the CFPB will focus on the following in its oversight work: Clear Information.

Compliance 78

Compliance Regulation Resources Policies 78

CFPB Monitor

SEPTEMBER 30, 2022

Market participants are advised by the FTC to keep the following three key principles in mind when conducting a BNPL compliance review: Misrepresentations regarding the cost of a product or the terms of the transaction, including associated fees, are deceptive and violate the FTC Act. On October 3, 2022, from 1 p.m.

Compliance 78

Compliance Retail Report Marketing 78

Abrigo

FEBRUARY 23, 2023

Takeaway 3 With effective technology, the bank can continue to grow its portfolio without necessarily adding staff. Worried about complying with the CFPB 1071 rule? Check out our 1071 compliance resources. Takeaway 2 Small banks can better serve customers when they free up staff to focus on fostering relationships.

Community Bank 195

Community Bank Kansas City Community Lending 195

Abrigo

JUNE 23, 2023

You might also like this on-demand webinar on the new CFPB small business data collection rule Watch Takeaway 1 Banks and credit unions often face challenges implementing data warehouses and are not pleased with the result. Stay up to date on the CFPB 1071 data collection rule and other lending compliance topics.

Data 195

Data Lending System Management 195

CFPB Monitor

FEBRUARY 28, 2022

The CFPB recently issued a factsheet addressing how prepaid interest, also referred to as per diem interest, factors into the calculation of the annual percentage rate (APR) for certain adjustable rate mortgage (ARM) loans and step-rate loans for purposes of assessing qualified mortgage (QM) loan status under the revised general QM rule.

Examples 78

Examples Payments Compliance Report 78

CFPB Monitor

OCTOBER 20, 2016

On October 17, the FDIC released revised interagency Military Lending Act (MLA) examination procedures for use in connection with consumer credit transactions occurring on or after October 3, 2016. The FDIC also provided guidance on its initial supervisory expectations for examinations relating to MLA compliance.

FDIC 60

FDIC Compliance Training Lending 60

CFPB Monitor

AUGUST 31, 2016

According to Politico, Holly Petraeus, Assistant Director of the CFPB’s Office of Servicemember Affairs, will be retiring from the CFPB. During her tenure at the CFPB, the protection of military servicemembers and their families has been a focus of CFPB supervisory and enforcement activity. Among other things, Ms.

Compliance 68

Compliance Lending Cards 68

CFPB Monitor

OCTOBER 6, 2016

On September 30, the CFPB released updated examination procedures for Military Lending Act (MLA) compliance. Compliance with the final rule amending the MLA, issued by the Department of Defense (DoD) in July 2015, was required for creditors of most consumer credit products as of this past Monday, October 3.

Compliance 99

Compliance Lending Policies Training 99

CFPB Monitor

FEBRUARY 4, 2019

For years, the mortgage industry has urged the CFPB to issue informal written guidance on the TILA/RESPA Integrated Disclosure (TRID) Rule, as well as other rules. The CFPB resisted, providing most guidance in the form of actual rules, webinars or oral statements. if a prepayment penalty has been added to the loan.

Compliance 94

Compliance Regulation Industry Policies 94

CFPB Monitor

OCTOBER 6, 2022

On October 4, 2022, the Consumer Financial Protection Bureau (CFPB) entered into a consent order with Choice Money, a New York nonbank remittance transfer provider involving violations of the Remittance Transfer Rule (“Remittance Rule”), Subpart B of Regulation E, 12 C.F.R. §§ 1005.30 to 1005.36, and the Consumer Financial Protection Act.

Policies 78

Policies Compliance Payments New York 78

CFPB Monitor

SEPTEMBER 2, 2016

The request was made in a letter to the CFPB, the Fed, the FDIC, the OCC, and the NCUA (Agencies). The DoD consulted with the CFPB in developing the final rule, and the CFPB actively supported the DoD’s plans to expand MLA coverage.

Compliance 79

Compliance Groups Lending FDIC 79

CFPB Monitor

FEBRUARY 7, 2019

The CFPB has issued highly-anticipated proposed revisions to its final payday/auto title/high-rate installment loan rule (Rule) that would rescind the Rule’s ability-to-repay provisions in their entirety (which the CFPB refers to as the “Mandatory Underwriting Provisions”). This proposal has a 30-day comment period.

Compliance 68

Compliance Payments Lending Study 68

CFPB Monitor

OCTOBER 25, 2022

Under the settlement, Rhinebeck will pay a $950,000 civil money penalty, provide restitution to borrowers, and develop a compliance plan which includes updates to its auto policies to cap dealer markups on installment contracts purchased by the bank. to 2.5% (and up to 3%, in a small number of cases) depending on the term of the contract.

New York 78

New York Lending Community Bank Community 78

CFPB Monitor

AUGUST 21, 2020

As promised by the CFPB when it issued two Regulation Z ability to repay rule qualified mortgage (QM) loan proposals in June 2020 , the CFPB recently issued a proposal to provide for a new seasoned QM loan. Comments will be due 30 days after the proposal is published in the Federal Register.

Compliance 78

Compliance Regulation Payments National 78

Abrigo

MAY 18, 2023

Takeaway 3 Use these tools to consider how much their resources can support while meeting regulatory expectations. WATCH Takeaway 1 Scope and depth are useful evaluation benchmarks for your financial institution's loan review process. Scope and depth Why use scope and depth to discuss loan review?

Lending 195

Lending Training Guidelines Policies 195

Jeff For Banks

APRIL 4, 2024

Regulation and the Political Environment "Last month, the CFPB reported how banks have become more dependent on these fees to feed their profit model on checking accounts. As well as compliance, fraud, credit, reconciliations, reporting, and other risk mitigation that is currently performed in a resource intensive way.

Banking Trends 119

Banking Trends Trends Millennials Oregon 119

CFPB Monitor

FEBRUARY 6, 2019

c)(3), (d)(2)(ii). Thus, a decision by the Department of Education or Congress characterizing lead generators as third-party servicers would likely carry a significant compliance burden for both lead generators and contracting schools. See 34 C.F.R.

Groups 60

Groups Compliance Regulation Industry 60

CFPB Monitor

JANUARY 14, 2016

The CFPB has released a report for FY 2015 prepared by KPMG LLP of its independent audit of selected CFPB operations and budget. KPMG did not identify any findings related to the CFPB’s budget process or IRB process but made several recommendations for strengthening those processes.

Policies 60

Policies Compliance Regulation Operations 60

CFPB Monitor

DECEMBER 9, 2021

The CFPB has issued a final rule amending Regulation Z to address the discontinuation of the London Inter-Bank Offered Rate (LIBOR) that is currently used by many creditors as the index for calculating the interest rate on credit cards and other variable-rate consumer credit products. Dollar LIBOR index.

Regulation 78

Regulation Cards Compliance Groups 78