The Dodd-Frank Act requires the CFPB to conduct an assessment of each “significant rule” adopted by the Bureau. The Bureau has determined that the TILA/RESPA Integrated Disclosure (TRID) Rule qualifies as a “significant rule.” Assessment reports must be published no later than five years after the effective date of the rule being assessed. The TRID

The CFPB has published its Fall 2019 rulemaking agenda as part of the Fall 2019 Unified Agenda of Federal Regulatory and Deregulatory Actions, which is coordinated by the Office of Management and Budget.  It represents the CFPB’s second rulemaking agenda under Director Kraninger’s leadership.  The agenda’s preamble indicates that the information in the agenda is

We are pleased to share with our readers that Ballard Spahr has launched a new blog, Ballard360 Insider.

The firm’s new blog explores trends and best practices in legal operations and innovation.  It provides timely, practical insights, keeping pace with the latest developments, challenges, and opportunities in technology, matter management, strategic pricing, and client

The U.S. Department of Treasury recently issued the long-awaited Housing Reform Plan, and among various topics the Plan addresses the temporary qualified mortgage under the Regulation Z ability-to-repay rule for loans that are eligible for sale to Fannie Mae or Freddie Mac (the GSEs). The Department concurs with the position of the CFPB, set

In this podcast, we discuss in detail certain provisions of the CFPB’s Proposed Debt Collection Rule that create the possibility of a collector providing disclosures to consumers by means of electronic communications. Among other things, we detail the scope, requirements and limitations related to such electronic communications, review the logistical challenges the Rule poses as

On August 14, 2019, Senate Banking Committee Ranking Member Sherrod Brown (D-Ohio) wrote a letter imploring Consumer Financial Protection Bureau Director Kathy Kraninger to implement the payments provisions of the 2017 Payday Rule by the scheduled August 19, 2019, compliance date, by requesting a lifting of the stay imposed by the Texas federal district court

The Texas federal district court hearing the lawsuit filed by two trade groups challenging the CFPB’s final payday/auto title/high-rate installment loan rule (Payday Rule) entered an order on August 6 that once again continues the stay of the lawsuit and the August 19, 2019 compliance date for both the Payday Rule’s ability-to-repay (ATR) provisions and

In this podcast, we look at the unique challenges that the CFPB’s proposal may create for student loans.  Our discussion focuses on how the proposal’s call attempt limits, time/place limits for calls, texts, and e-mails, and special restrictions that apply to the aggregation of multiple student loans could impact communications with borrowers.

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The CFPB and the two industry trade groups that filed a lawsuit in a Texas federal district court challenging the CFPB’s final payday/auto title/high-rate installment loan rule (Payday Rule) filed a new status report with the court on August 2.

The status report references the CFPB’s proposal to revise the Payday Rule to rescind the