The CFPB has issued a new small entity compliance guide: “Payday, Vehicle Title and High-Cost Installment Lending Rule: Payment-Related Provisions.”

The CFPB has proposed to revise its final payday/auto title/high-rate installment loan rule to rescind the rule’s ability-to-repay (ATR) provisions in their entirety and to delay the compliance date for the ATR provisions

The American Bankers Association and the Bank Policy Institute have sent a letter to the Board of Governors of the Federal Reserve System (Fed) to petition the Fed to engage in rulemaking to clarify the Fed’s September 2018 “Interagency Statement Clarifying the Role of Supervisory Guidance” (the “Interagency Statement”).  The Interagency Statement was

Republican Congressman Blaine Luetkemeyer, a member of the House Financial Services Committee, has sent letters to six agencies asking them to issue and publish statements concerning the effect and use of “agency statements-for example, guidance documents, supervisory letters or examination manuals—that have not gone through notice and comment rulemaking.”  One such letter was sent to

We previously reported that Congress might have the opportunity to disapprove the CFPB’s disparate impact theory of assignee liability for so-called auto dealer “markup” disparities because the CFPB Bulletin describing its theory was determined by the General Accountability Office (GAO) to be a “rule” subject to override under the Congressional Review Act (CRA).  Our hope

Politico has reported that Republican Senator Jerry Moran has introduced a resolution under the Congressional Review Act (CRA) to overturn the CFPB’s 2013 auto finance guidance.

The guidance is set forth in CFPB Bulletin 2013-02, titled “Indirect Auto Lending and Compliance with the Equal Credit Opportunity Act” (Bulletin).  In December 2017, in response to a

The CFPB has issued a new compliance bulletin (2017-11) to provide guidance on pay-by-phone fees.  The guidance includes examples of conduct relating to pay-by-phone practices identified by the CFPB in its supervision and enforcement activities that may violate or risk violating the Dodd-Frank UDAAP prohibition or the FDCPA.

The enforcement actions cited in

The CFPB published today a final list of the rules it will enforce.  The final list includes two rules that weren’t on the initial list the CFPB published for comment last month: the FTC’s Mortgage Acts and Practices-Advertising rule, and HUD’s rule implementing the SAFE Act (which takes effect this August 29).  How comfortable should