The CFPB recently issued an advance notice of proposed rulemaking (ANPR) requesting comments on how to revise the qualified mortgage (QM) provisions of the Regulation Z ability to repay rule in view of the impending expiration of the temporary QM for loans that meet the statutory QM criteria and are eligible for purchase or guaranty

In this podcast, we review what’s in the proposed limits and examine the challenges they present for collectors, including the retroactive lookback for call attempts and successful contacts, the treatment of ringless calls, calls placed at the consumer’s request, and the impact of call blocking technology.  We also discuss the implications for first party collections

Seven consumer advocacy groups have submitted a letter to Director Kraninger requesting a two-month extension of the August 19 comment deadline for the CFPB’s proposed debt collection rules.

The groups state in their letter that “there are very few organizations that represent the interests of people subject to debt collection that have the expertise and

While directed at third party debt collectors, the CFPB’s proposed rules, if adopted, would significantly impact creditors and their first party collection partners.  In this podcast, we look at the actions the proposal would require creditors to take before assigning a debt for collection, what the proposal would mean for third party oversight, and how

In this week’s podcast, we take a close look at the CFPB payday loan rule’s payment provisions that could become effective as early as this August if the current court stay is lifted.  After reviewing the limits and disclosures mandated by the payment provisions, we explain why the provisions are deeply flawed and discuss the

Last month, Ballard Spahr submitted two letters to the CFPB, critiquing the payment provisions of the CFPB’s final payday/auto title/high-rate installment loan rule (the “Payment Provisions”).  Last Friday, the Bureau delayed the implementation date of the rule’s mandatory underwriting provisions by 15 months, to November 19, 2020.  However, the Payment Provisions are scheduled to go

The CFPB has issued a final rule delaying the compliance date for the ability-to-repay (ATR) provisions in its final payday/auto title/high-rate installment loan rule (Payday Rule) for 15 months, until November 19, 2020.

The Supplementary Information accompanying the final rule expressly states that the Bureau is not delaying the August 19, 2019 compliance date for

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 yesterday 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 its payment