With the release of its examination procedures for credit  bureaus and consumer reporting agencies, the CFPB is now one step closer to scheduling examinations for the 30 largest companies that it estimates account for about 94 percent of the market (measured by annual receipts). These are the companies it has deemed, by rule effective September 30, to be the larger participants in this market.… Continue Reading

Next Monday, September 10, the federal financial regulatory agencies will host an interagency discussion on servicemember protections and SCRA compliance issues. The discussion topics include:

  • Permanent Change of Station Guidance
  • HAMP Enhancements
  • Short Sale Assistance for Military Homeowners
  • Recent Enforcement Actions
  • SCRA Compliance Tips

The discussion will be followed by a Q&A session.… Continue Reading

After reanalyzing certain sample loan level data, the CFPB announced that it is not making any changes to the key findings and recommendations in its July report to Congress on private student loans.  The CFPB had posted a “research note” on its website to accompany the report disclosing that it had been informed by the lenders who provided the sample lender loan level data that the manner in which it had analyzed certain data could produce incomplete results. … Continue Reading

In July, the CFPB proposed amendments to Regulation Z (TILA) and Regulation X (RESPA) to implement various provisions of the Dodd-Frank Act.   Those proposals included an expansion of the definition of “finance charge” to include additional charges, and a new test for determining when a mortgage meets the APR trigger for a “high-cost mortgage” to offset the expanded finance charge. … Continue Reading

Last month, the CFPB issued its second Semi-Annual Report to the President and Congress covering the CFPB’s activities from January 1 through June 30, 2012. 

The Financial Services Committee has announced that it will be holding a hearing on Thursday, September 20, 2012 at 10 a.m. to review and discuss the report with CFPB Director Richard Cordray.… Continue Reading

UniversityRecent remarks by Rohit Chopra, the CFPB’s Student Loan Ombudsman, to the Congressional Forum on Student Loans and in an interview with Bloomberg Radio could presage new CFPB student loan recommendations to Congress or even CFPB examinations, investigations, and/or rulemaking proceedings. 

In his remarks to the Congressional Forum, Mr. Chopra analogized student loan borrowers who did not receive the value they expected for their loans to “underwater” homeowners.… Continue Reading

Last week, we reported that Leonard Chanin was leaving his position as Assistant Director for Regulations at the CFPB to return to private practice. His departure has now been officially announced by Director Cordray, together with a series of staffing changes.  Among those changes is that Kelly Thompson Cochran, who has been serving as the CFPB’s Deputy Assistant Director for Regulations, will assume Leonard’s responsibilities and serve as the Acting Assistant Director for Regulations. … Continue Reading

Vote ButtonsThe ABA Journal is collecting suggestions for its Blawg 100, an annual listing of the 100 best legal blogs. After creating our blog just more than a year ago, and publishing nearly 300 posts, we’re hoping to make the list. If you read CFPB Monitor regularly and think the ABA Journal should consider us, let them know by clicking here.… Continue Reading

Leonard Chanin, Assistant Director of the CFPB’s Office of Regulations, is leaving the CFPB to return to private practice.  

Leonard’s departure comes at a critical time because of the myriad of regulations the CFPB must finalize by January 21 of next year. Before joining the CFPB, Mr. Chanin worked in the Fed’s Division of Consumer and Community Affairs, where he served as the Division’s Deputy Director, and he was among the more senior of the Division’s attorneys who moved to the CFPB.  … Continue Reading

It appears a flat loan origination fee requirement wasn’t such a good idea after all.  That’s the conclusion the CFPB came to in its proposal issued on August 17 to integrate the Dodd-Frank mortgage loan originator compensation provisions with the existing Regulation Z provisions, and implement Dodd-Frank loan originator requirements. 

We have prepared a legal alert that discusses the proposal and how it differs from the CFPB’s description in May of the issues it was then considering.… Continue Reading