The CFPB’s latest report card on its information security system, delivered last week by the Bureau’s Office of Inspector General (OIG), indicates that the system still needs improvement.  In May 2012, the Government Accountability Office issued a report that identified various problems with the CFPB’s internal controls and accounting systems that included the absence of an agency-wide information security program for the information and information systems that support the CFPB’s financial reporting, operations, and assets. … Continue Reading

The Financial Aid Shopping Sheet prepared by the CFPB and the Department of Education will now receive its litmus test.  Last week, Secretary of Education Arne Duncan announced in a blog post on the DOE’s web site that more than 500 colleges and universities have agreed to use the Shopping Sheet for financial aid awarded during the 2013-2014 school year. … Continue Reading

On November 16, a federal district judge in California entered a preliminary injunction in favor of the CFPB in the action it filed this past July against a law firm that offered mortgage assistance relief services to consumers.  In its complaint, the CFPB alleged that the law firm and various individuals and companies duped consumers by falsely promising loan modifications in exchange for advance fees and, in reality, did little or nothing to help consumers.    … Continue Reading

The CFPB has issued its Financial Report for fiscal year 2012.  The report is divided into two parts: one part contains management’s discussion and analysis and the second part contains the CFPB’s financial statements and note disclosures. 

The report indicates that the CFPB grew from about 663 employees as of the end of FY 2011 to 970 as of the end of FY 2012 (which ended September 30).  … Continue Reading

The CFPB and FTC announced that they have sent warning letters to mortgage advertisers urging them to review their marketing materials to ensure that they comply with the Mortgage Acts and Practices-Advertising Rule (Regulation N) and other applicable law.  The warning letters were the subject of the press call the CFPB and FTC had promoted in the media advisory they issued last week.  … Continue Reading

The CFPB’s initiatives to address elder financial abuse were the focus of testimony last week by Hubert H. “Skip” Humphrey III, the CFPB’s Assistant Director for the Office of Older Americans, to the Senate’s Special Committee on Aging.  As we have previously commented, we consider helping consumers aged 62 and older to protect themselves from financial abuse and make sound financial decisions to be one of the CFPB’s most worthwhile Dodd-Frank mandates. … Continue Reading

On November 16, the CFPB adopted a temporary exemption for certain mortgage disclosure requirements added by the Dodd-Frank Act to allow the disclosures to be implemented along with the proposal to integrate the Real Estate Settlement Procedures Act and Truth in Lending Act disclosures.  Without the temporary exemption, industry would have been required to begin providing the new disclosures as of January 21, 2013.… Continue Reading

The FTC has just issued a media advisory inviting credentialed members of the media to participate in a press call  that the FTC and CFPB will hold at noon EST on Monday “to announce a coordinated effort to protect consumers.”  The key participants will be Kent Marcus, CFPB Assistant Director of Enforcement, and Thomas Pahl, FTC Assistant Director of the Division of Financial Practices. … Continue Reading

With the January 1, 2013 deadline for using the new CFPB model FCRA forms on the horizon, the CFPB apparently took another look at those forms and realized that they contained a few glitches.  On November 14, the CFPB published a notice in the Federal Register correcting various typos and technical errors, effective immediately. … Continue Reading

I regularly work with technology innovators to help them get their ideas cleaned up for financial institutions and to give them a headstart in understanding the types of risk concerns and controls that financial institutions are going to have and want.  To technology innovators who may be intrigued by the CFPB’s request for dialogue, I wanted to provide my thoughts on some steps to take before charging through the Project Catalyst doors and throwing your ideas in front of the CFPB.… Continue Reading