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The Center for Responsible Lending (CRL) and the Consumer Bankers Association (CBA) have filed a joint petition with the CFPB that urges the Bureau to engage in rulemaking to define larger participants in the market for personal loans.  In February 2022, the CFPB established a new procedure for members of the public to submit petitions for rulemaking (including amendments to or repeals of existing rules). … Continue Reading

Eight national trade groups have filed a petition with the CFPB that urges the Bureau to engage in rulemaking to define larger participants in the market for data aggregation services.  The trade groups are the American Bankers Association, Consumer Bankers Association, Credit Union National Association, Housing Policy Counsel, Independent Community Bankers of America, National Association of Federally Insured Credit Unions, National Bankers Association, and Clearing House Association. … Continue Reading

The Consumer Bankers Association has sent a letter to Rohit Chopra, the incoming CFPB Director, in which it urges the CFPB to adopt a larger participant rule for fintech consumer lenders.

Under the Dodd-Frank Act, in addition to authority to supervise nonbank entities in the residential mortgage, private student lending, and payday lending markets, the CFPB has authority to supervise nonbank entities considered to be “a larger participant of a market for other consumer financial products or services.”  … Continue Reading

The CFPB’s Spring 2017 rulemaking agenda has been published as part of the Spring 2017 Unified Agenda of Federal Regulatory and Deregulatory Actions.  The preamble indicates that the information in the agenda is current as of April 1, 2017.  Accordingly, the agenda does not reflect the issuance of the CFPB’s final arbitration rule on July 10 or other rulemaking actions taken since April 1 such as the proposed changes to the CFPB’s prepaid account rule and various recent mortgage-related developments. … Continue Reading

The CFPB issued a final rule on June 10, 2015 allowing it to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.”  Relatedly, it adopted simultaneously a separate rule defining certain automobile leases as a “financial product or service.”  These rules will be effective 60 days after their publication in the Federal Register.… Continue Reading

Yesterday, the CFPB finalized its larger participant rule for nonbank auto finance companies, making them subject to supervision after the effective date of the rule.  But the Bureau’s press release and newly-released auto finance examination procedures, to me, are even more significant, because they signal areas of future concentration for the Bureau in examinations of both banks and nonbanks in the auto finance space.… Continue Reading

Just in time for the holiday weekend, the CFPB released its Spring 2015 rulemaking agenda last Friday.  The agenda sets the following timetables:

Prepaid financial products.  In November 2014, the CFPB issued a proposed rule for prepaid financial products, including general-purpose reloadable prepaid cards and certain digital and mobile wallets.  The agenda indicates that the CFPB expects to issue a final rule in January 2016.… Continue Reading

The CFPB has issued a proposal to supervise nonbank companies that qualify as “larger participants of a market for automobile financing.”  Comments on the proposal will be due 60 days after its publication in the Federal Register.

The proposal is based on the CFPB’s authority to supervise nonbank entities considered to be “a larger participant of a market for other consumer financial products or services.”… Continue Reading

Today is the final day of CBA Live 2014, which is being held at the Gaylord Hotel in National Harbor, MD.  I spoke at a program yesterday about the CFPB’s ongoing arbitration study under Section 1028 of Dodd-Frank.  Based on the CFPB’s December 12, 2013 partial release of data, I have predicted that the CFPB will, at a minimum, issue a proposed regulation next year banning the use of class action waivers. … Continue Reading

As we previously reported, last Friday House Financial Services Committee Chairman Jeb Hensarling (R-TX) sent a letter to CFPB Director Richard Cordray asking for a response by March 13 to specific questions about the methodology and analyses employed by the CFPB in determining whether dealer finance charge participations violate the Equal Credit Opportunity Act and Regulation B.… Continue Reading