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Another Maryland threat to bank partner model lending

CFPB Monitor

The OCFR claims that the Bank’s failure to hold the required lending licenses makes the loans unenforceable and prohibits Atlanticus/Fortiva from collecting any amounts on the loans. In addition, legal challenges to the OCC and FDIC “ Madden -fix” rules and the OCC’s “true lender” rule continue to create uncertainty for participants.

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Federal Reserve Releases 2021 CCAR Testing Scenarios

Perficient

The Fed’s Comprehensive Capital Analysis and Review (“CCAR”) stress tests are designed to ensure that large banks are able to lend to households and businesses even in a severe recession.

Exercises 309
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2022 Dodd-Frank Stress Test Scenarios Released

Perficient

Federal bank regulators work together to design Comprehensive Capital Analysis and Review (“CCAR”) stress tests that are designed to ensure that even in the case of a severe recession, significant banks can lend to households and businesses. dollar against those countries’ currencies.

Capital 294
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CFPB files reply in support of its cross-motion for summary judgment and continues to oppose delay of compliance date for payments provisions

CFPB Monitor

Because Seila Law did not find a problem with the authority of the Bureau itself but rather with the Director’s exercise of executive power on behalf of the Bureau, the payments provisions were not void from the start and can be validly ratified.

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CFPB Summer 2021 Supervisory Highlights looks at auto servicing, consumer reporting, debt collection, deposits, fair lending, mortgage origination and servicing, private student loans, payday lending, and student loan servicing

CFPB Monitor

Fair lending. In several examinations that identified such errors, the root causes were deficiencies in the institutions’ compliance management systems. Payday lending. CFPB examiners found widespread errors within 2018 HMDA loan application registers of several financial institutions.

Lending 78
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State AGs criticize CFPB plans to end MLA exams

CFPB Monitor

Section 987(f)(6)) that states the MLA “shall be enforced by the agencies specified in section 108 of the Truth in Lending Act (15 U.S.C. Section 987(f)(6)) that states the MLA “shall be enforced by the agencies specified in section 108 of the Truth in Lending Act (15 U.S.C. They cite to the MLA provision (10 U.S.C.

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Trade groups challenging CFPB payday loan rule file opening brief with Fifth Circuit

CFPB Monitor

The trade groups filed an appeal with the Fifth Circuit from the district court’s final judgment granting the CFPB’s summary judgment motion and staying the compliance date for the payment provisions until 286 days after August 31, 2021 (which would have been until June 13, 2022).

Groups 78