CFPB, Federal Agencies, State Agencies, and Attorneys General
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…
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…
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…
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…
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…
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…
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…
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…
Since last March, when the CFPB issued Bulletin No. 2013-02, its highly controversial release warning banks and finance companies that purchase motor vehicle installment sales contracts that, under existing law, any dealer finance charge participation may violate the Equal Credit Opportunity Act and Regulation B, numerous members of Congress have been unsuccessful in…
Later this week, on March 1, the CFPB’s final rule defining larger participants of the student loan servicer market becomes effective.
We expect the CFPB to immediately begin examining entities that qualify as larger participants. Under the rule, the CFPB can supervise servicing of private and federal student loans by any nonbank entity that qualifies…
