Reid F. Herlihy

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The CFPB will hold two virtual sessions later this month to answer questions about its Nonbank Enforcement Action Registry rule. The rule, issued in June 2024, will require certain nonbank entities to register certain covered administrative or court orders, and certain nonbank entities to comply with ongoing attestation requirements on the entity’s compliance with such orders

The two sessions—the first on December 11 and the second on December17—will feature staff from the bureau’s Nonbank Registration Team.… Continue Reading

The U.S. Department of Veterans Affairs (VA) recently proposed rules to modify the requirements for the reporting of VA guaranteed mortgage loans, and the rules regarding when the VA would assert a defense for a partial or total loss of a guaranty for a VA guaranteed mortgage loan.  Comments on the proposal are due by January 21, 2025.… Continue Reading

Saying that it wants to provide sufficient time to brief issues in pending litigation, the CFPB has announced that it is extending the effective date of its advisory opinion on medical debt from Dec. 3, 2024 to Jan. 2, 2025.

ACA International, the association representing the accounts receivable industry, has filed suit in the U.S.… Continue Reading

ACA International, the association representing the accounts receivable industry, has filed suit against the CFPB, alleging that the bureau’s advisory opinion on medical debt was overtly political, issued in violation of the Administrative Procedures Act (APA) and should be nullified.

The association charged that although the CFPB was designed to be independent, the bureau’s advisory opinion was announced at an event at the White House and was first introduced by Vice President Kamala Harris, who at the time was running for president.… Continue Reading

California Gov. Gavin Newsom has signed legislation covering a range of consumer protection issues. The bills aim to “strengthen protections for consumers, addressing issues that have put financial strain on Californians while setting new standards for transparency and accountability across industries.”

The legislative package includes the following bills:

  • AB 2017 prohibits state-chartered banks and credit unions from charging nonsufficient funds fees when a transaction is declined instantaneously or near instantaneously for insufficient funds.
… Continue Reading

The Federal Emergency Management Agency (FEMA) has announced it will allow National Flood Insurance Program (NFIP) premiums to be paid on an installment basis. The final rule implements an installment payment option that was mandated by Congress in the Biggert-Waters Flood Insurance Reform Act, adopted in 2012, for policyholders who are not required to pay into escrow for flood insurance premiums. … Continue Reading

The CFPB is in the process of completing its final rule intended to ban the inclusion of medical debts in credit reports, bureau Director Rohit Chopra said at a White House session intended to focus on practices in the medical debt collection industry.

“Often, predatory companies threaten to put medical debt on people’s credit reports, where lenders, landlords, and employers presume their accuracy,” Chopra said, in his prepared remarks.… Continue Reading

The CFPB recently issued a blog post, highlighting debt collection impacts on surviving spouses. In the blog, the CFPB warns that debt collectors who try to collect on a spouse’s medical bills from a survivor, who is not legally liable for the bills, may violate the Fair Debt Collection Practices Act and state law.… Continue Reading

The House and Senate on September 25, 2024 passed legislation that would extend key parts of the National Flood Insurance Program (NFIP) until December 20, 2024. The extension is included in H.R. 9747, which also would provide funds for much of the federal government to keep operating until that date.

President Biden has said he will sign the legislation.… Continue Reading

As interest rates drop, the CFPB is exploring ways to streamline mortgage rules to make the refinancing process easier and closing costs less expensive, Director Rohit Chopra said at a housing conference sponsored by the Center for American Progress.

 “When an existing or competing lender is seeking to refinance a loan with a much lower rate for a substantially similar mortgage, it may not be worthwhile for the lender to repeat many of the steps that were taken during the purchase process,” Chopra said.… Continue Reading