The CFPB has issued its fourth Semi-Annual Report to the President and Congress.  Although the report’s cover page indicates that it covers the period April 1 to September 30, 2013, this would appear to be a mistake since the CFPB’s third Semi-Annual Report covered the period from July 1 through December 31, 2012.  Accordingly, the fourth report presumably covers the period from January 1 to June 30, 2013. 

As did the CFPB’s previous Semi-Annual Reports, much of the information in the report was the subject of our previous blog posts and is a recycling of information contained in various other CFPB reports.  We did, however, find the following information to be noteworthy: 

  • The CFPB “continues to work toward a rulemaking” on prepaid cards in the “upcoming period.”  While the CFPB does not specifically indicate what is meant by the “upcoming period,” it would appear to be July 1 through December 31, 2013, the period to be covered by the CFPB’s fifth Semi-Annual Report.
  • In the “upcoming period,” the CFPB is “accelerating work” to develop a proposal to implement Dodd-Frank’s expanded data collection requirements.
  • The CFPB states that it is assessing whether rulemaking is warranted to address issues identified in connection with payday loans and deposit advance products and that it continues to evaluate its policy options with respect to overdraft programs.
  • The only mention of arbitration in the report is in the appendix containing a list of the CFPB’s significant orders issued during the past year (Sept. 30, 2012 to Sept. 30, 2013).  Included in the list are “Orders to secure sample sets of consumer agreements for an arbitration study of standard form checking account agreements.”  The CFPB notes that the orders were issued in September 2013 pursuant to Section 1022(c)(4) of Dodd-Frank. Curiously, the CFPB also includes these orders in another appendix listing orders issued to nonbanks.
  • In the “upcoming period,” the CFPB will “propose additional rules to further define the scope of the Bureau’s nonbank supervision.”  We have been expecting the CFPB’s issuance in 2013 of a proposed larger participant rule for auto finance companies.  That action may happen as soon as next Thursday, November 14, in connection with the CFPB’s auto finance forum scheduled for that day.