larger participant rule

On Monday the CFPB released updated examination procedures for student loans.  This update revises and expands on a previous update that was released in December 2013 in conjunction with the CFPB’s “larger participants” rule for student loan servicers. The new procedures serve to offer CFPB examiners more detailed guidance for examining student loans servicers subject to the CFPB’s supervisory authority, including banks, private student loan lenders, and others servicers subject to CFPB supervision under the Bureau’s “larger participants” rule.… Continue Reading

On Friday, August 3, I had the pleasure of speaking on a panel at the ABA Annual Meeting with Meredith Fuchs, General Counsel of the CFPB, and Michael Gordon, Senior Counselor to the Director of the CFPB.  Also on the panel were Mark Metz from Bank of America, Jean Noonan from Hudson Cook, and Reginald Brown from Wilmer Hale, who did a great job moderating.… Continue Reading

On Monday, the CFPB issued its final rule defining larger participants of a market for consumer reporting. It acted pursuant to Section 1024 of Dodd-Frank which grants the CFPB the authority to supervise non-bank covered persons for compliance with Federal consumer financial laws. Dodd-Frank automatically gave the CFPB the authority to supervise non-bank covered persons in the residential mortgage, private education lending and payday lending industries.… Continue Reading

Credit ScoresThe CFPB will hold a public field hearing and panel discussion on credit reporting on July 16 at the Detroit Institute of Arts. The hearing appears to coincide with the CFPB’s anticipated release of the final “larger participant” rule, which must be issued no later than July 21.

Earlier this year, the CFPB issued a proposed rule defining the minimum size of credit bureaus, debt buyers, and debt collectors that it will supervise and examine.… Continue Reading