CFPB, Federal Agencies, State Agencies, and Attorneys General
As previously reported, in May 2019 the CFPB issued both a proposal to modify the Home Mortgage Disclosure Act (HMDA) rule, and an advance notice of proposed rulemaking seeking comment on three specific aspects of the HMDA rule:
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As previously reported, in May 2019 the CFPB issued both a proposed rule to modify the existing Home Mortgage Disclosure Act (HMDA) rule and an advance notice of proposed rulemaking seeking comment on additional potential changes to the rule. The drafts of the items indicate a 30 day comment period for the proposed rule…
The CFPB recently issued both a proposed Home Mortgage Disclosure Act (HMDA) rule and an advance notice of proposed HMDA rulemaking. The CFPB also issued a summary that mainly focuses on the proposed rule, as well as an unofficial redline of how the proposed rule would amend the HMDA rule, known as Regulation C. …
As we stated in Monday’s blog, the purpose of the CFPB’s Town Hall taking place on May 8 in Philadelphia will likely be to announce the notice of proposed debt collection rulemaking. It has been announced by ACA International that CEO, Mark Neeb, has been invited to participate in the Town Hall. There is…
Earlier today, the Bureau of Consumer Financial Protection released a Public Statement Regarding Payday Rule Reconsideration and Delay of Compliance Date. Echoing rumors that have been circulating in the industry for several weeks (which we had agreed not to address in our blog), the Statement reads in full as follows:
The Bureau expects to …
On September 19, 2018, the Georgia based Cooperative Baptist Fellowship (the “Fellowship”) filed a motion to intervene as a defendant in a case filed by the Community Financial Services Association of America Ltd. and the Consumer Service Alliance of Texas challenging the CFPB’s Payday Rule. The lawsuit was filed in April 2018 claiming, among other…
On this week’s podcast, Ballard Spahr attorneys Bo Ranney, Chris Willis, and Reid Herlihy discuss the significant takeaways from the CFPB’s new report—the first edition of Supervisory Highlights issued under Acting Director Mick Mulvaney. Mr. Ranney, former Examiner-in-Charge at the CFPB, and Mr. Willis, who chairs Ballard Spahr’s Consumer Financial Services Litigation Group, discuss the…
In what seems to be a response to the Government Accountability Office’s (“GAO”) determination that the Consumer Financial Protection Bureau’s indirect auto finance bulletin (the “Bulletin”) was a rule subject to the Congressional Review Act (“CRA”) and a rebuke to the Bureau’s prior approach of “rulemaking by enforcement,” the Board of Governors of the Federal…
The CFPB recently released an interpretive and procedural rule to implement and clarify the partial exemption from the Home Mortgage Disclosure Act (HMDA) adopted in the Economic Growth, Regulatory Relief, and Consumer Protection Act (also known as S.2155).
As we reported previously, the Act amended HMDA to create an exemption applicable to the new…
The Consumer Financial Protection Bureau (CFPB) recently issued a statement regarding the partial exemption from Home Mortgage Disclosure Act (HMDA) reporting requirements for certain lower mortgage volume depository institution lenders that was adopted in the Economic Growth, Regulatory Relief, and Consumer Protection Act (Act).
As we reported previously, the Act exempts depository institutions and…
