CFPB examination procedures

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On September 30, the CFPB released updated examination procedures for Military Lending Act (MLA) compliance. Compliance with the final rule amending the MLA, issued by the Department of Defense (DoD) in July 2015, was required for creditors of most consumer credit products as of this past Monday, October 3. The final rule applies to all consumer credit transactions or accounts for consumer credit “consummated or established” on or after October 3, 2016.… 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

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