CFPB, Federal Agencies, State Agencies, and Attorneys General
In addition to rescinding seven policy statements providing flexibility to companies in meeting certain compliance obligations during the pandemic, the CFPB has also rescinded its 2018 bulletin (2018-01) that announced changes to supervisory communications. The Bureau has replaced the 2018 bulletin with a new bulletin (2021-01).
In the 2018 bulletin, the Bureau announced that it…
The CFPB has issued “Supervisory Highlights COVID-19 Prioritized Assessments Special Edition.”
The report indicates that in May 2020, the Bureau rescheduled about half of its planned examinations and instead conducted prioritized assessments (PAs) in response to the COVID-19 pandemic. The Bureau describes PAs as “higher-level inquiries than traditional examinations [that are] designed to…
Coming on the heels of the Presidential election results, the CFPB circulated an internal e-mail suspending a reorganization that would have stripped the Office of Enforcement’s autonomy to open investigations and issue civil investigative demands.
Bloomberg Law reported the suspension after obtaining a copy of the internal e-mail. According to the Bloomberg article, Bryan Schneider,…
We review the following findings and discuss their compliance implications: FCRA violations based on obtaining credit reports without a permissible purpose, incorrectly reporting the date of first delinquency, failing to conduct reasonable dispute investigations; Reg. E violations based on waivers of consumers’ dispute rights, use of incorrect date to determine timeliness of error notices, providing…
We review the CFPB’s findings that lenders engaged in deceptive practices and violated Regulation Z advertising requirements based on the following conduct and discuss the findings’ compliance implications: false representations about consumers’ ability to apply for loans online and the absence of credit checks; false threats in collection letters about lien placement, asset seizure, and…
The CFPB has released the Winter 2020 edition of its Supervisory Highlights. The report discusses the Bureau’s examinations in the areas of debt collection, mortgage servicing, payday lending, and student loan servicing that were completed between April 2019 and August 2019.
Key findings include the following:
Debt collection. One or more debt collectors…
The CFPB has issued a policy statement to clarify the Dodd-Frank Act’s abusiveness standard. The policy statement, which is applicable as of January 24, 2020, states that it describes “certain aspects of how [the Bureau] intends to approach its use of the abusiveness standard in its supervision and enforcement matters going forward.”
In the Supplementary…
The CFPB has issued a special edition of its Supervisory Highlights that focuses on compliance with the FCRA and Regulation V. The report contains two main sections, with one devoted to supervisory observations at furnishers and the other devoted to supervisory observations at consumer reporting companies (CRCs). (The report was published in yesterday’s Federal Register…
The CFPB has released the Summer 2019 edition of its Supervisory Highlights. The report discusses the Bureau’s examination findings in the areas of automobile loan originations, credit card account management, debt collection, furnishing, and mortgage originations.
Key findings include the following:
Auto loan originations. Auto lenders were found to have engaged in an abusive…
Last week, the FDIC published its Consumer Compliance Supervisory Highlights that provides observations about its consumer compliance supervision activities in 2018. Importantly, the highlights include anonymized 2018 exam findings regarding violations of consumer protection laws and other information to help financial institutions stay abreast of issues and trends identified during exams and assist them in…
