The U.S. Department of Treasury recently issued the long-awaited Housing Reform Plan, and among various topics the Plan addresses the temporary qualified mortgage under the Regulation Z ability-to-repay rule for loans that are eligible for sale to Fannie Mae or Freddie Mac (the GSEs). The Department concurs with the position of the CFPB, set
CFPB Rulemaking
CFPB Extends Comment Period for HMDA ANPR
By Richard J. Andreano, Jr. on
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:
- The new data points added by the CFPB based on discretionary authority.
- The free-form text fields
…
HMDA Proposed Rule Comment Period
By Richard J. Andreano, Jr. on
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…
CFPB Issues Proposed HMDA Rule and Advance Notice of Proposed Rulemaking
By Richard J. Andreano, Jr. on
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. …
CFPB’s Debt Collection Town Hall
By Alan S. Kaplinsky on
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…
CFPB issues statement regarding plans to reconsider payday loan rule
By Ballard CFS Group on
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…
Baptist Church Seeks to Intervene In CFPB Payday Rule Lawsuit
By Jenny N. Perkins on
Posted in Payday Lending, Regulatory and Enforcement
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…
This Week’s Podcast: CFPB Summer 2018 Supervisory Highlights
By Alan S. Kaplinsky on
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…
Five federal regulators issue statement clarifying role of supervisory guidance; Ballard Spahr to discuss interagency statement in Oct. 10 webinar on CFPB’s Summer 2018 Supervisory Highlights
By Ballard CFS Group on
Posted in Federal Agencies, Regulatory and Enforcement
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…
CFPB Provides Additional Guidance on HMDA Partial Exemption
By Richard J. Andreano, Jr. on
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…