In its final rule on Disclosure of Records and Information published last week, the CFPB gave no ground on its position that it has discretionary authority to share confidential information with state attorneys general.   This has been a significant concern to industry since the rule was published as an interim final rule in July 2011. 

TransparencyRecall that when the CFPB launched the Consumer Complaint Database, its expressed hope that “the marketplace of ideas” – i.e., the public – would study and analyze the information disclosed in the database in order to “determine what the data show[s].” 77 FR 37559. The CFPB also stated that the purpose of the database

On January 30, 2012, the American Bankers Association delivered a comment letter  to the CFPB in which it expressed strong disagreement with the CFPB’s proposed policy statement on “Disclosure of Certain Credit Card Complaint Data“. The ABA expressed concern that the complaint data will not help and may actually mislead consumers because it

The CFPB has launched a third round of testing in its “Know Before You Owe” project. Last month, as we reported, the CFPB began testing and requested public input on two revised prototypes (named Mimosa and Sassafras) of a mortgage loan settlement disclosure combining the final TILA disclosure and the RESPA HUD-1 Settlement Statement.

Two notices with requests for comments recently published by the CFPB present prime opportunities for banks and other regulated institutions to engage with the CFPB not only to positively impact the CFPB’s processes and procedures, but also to demonstrate that banks seek to develop a relationship of cooperation and collaboration with the CFPB.

On October

On November 1, 2011, Raj Date made a presentation to the House Financial Services Committee, outlining what the CFPB has done in its first 100 days, and previewing some of its future plans.  In large part, the presentation served to underscore the CFPB’s accomplishments since July 21, including the development of the “Know Before You

In an earlier post about the CFPB’s “Know Before You Owe” project, I commented that it was unclear how the CFPB intended to approach required RESPA/TILA disclosures other than the early TILA disclosure and the RESPA good faith estimate. The project was launched in May to design a simplified mortgage loan disclosure combining the disclosures