On June 4, the CFPB, jointly with the Fed, FDIC, NCUA and OCC, announced that the agencies were releasing a “Memorandum of Understanding on Supervisory Coordination” (MOU). The MOU was signed by the CFPB on May 3 and by the other agencies on various dates in May, with the Fed and NCUA signing last on May 16. … Continue Reading
June 2012
CFPB finalizes rules on procedures for investigations, enforcement and state official notifications
By Barbara S. Mishkin on
Posted in CFPB Rulemaking, Regulatory and Enforcement
The CFPB has finalized the following three rules which were issued as interim final rules in July 2011:
- Rules Relating to Investigations which set forth the CFPB’s policies and procedures for conducting investigations
- Rules of Practice for Adjudication Proceedings which set forth procedures for administrative enforcement actions initiated by the CFPB
- State Official Notification Rule which sets forth procedures to be used by state officials to provide notice to the CFPB of any proceedings they initiate to enforce the Dodd-Frank Act or CFPB regulations.
Native American tribal payday lending continues to spark debate
By Barbara S. Mishkin on
Posted in Payday Lending, Regulatory and Enforcement
Native American tribal payday lending is on the radar screens of the CFPB and the FTC, as reflected in recent comments from CFPB Director Richard Cordray and FTC Commissioner Julie Brill. More specifically, the agencies have been raising questions about the use of tribal immunity as a defense to state usury laws. … Continue Reading
CFPB seeks more input on ability-to-repay rule
By Richard J. Andreano, Jr. on
Consistent with recent rumors, it’s now looking more likely that adoption of a final ability-to-repay/qualified mortgage rule by the CFPB will not happen until after the November elections. On May 31, the CFPB reopened the comment period on the proposed rule. (The original comment period closed on July 22, 2011.) The CFPB’s notice of the reopening seeks specific data and loan information by July 9, 2012.… Continue Reading