larger participant

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On May 23, 2012, the CFPB published an advanced notice of proposed rulemaking (ANPR) that proposes to extend Regulation E protections to GPR cards. The CFPB’s release of this ANPR coincided with the CFPB’s scheduled hearing in Durham, North Carolina on the same subject. We previously issued an e-alert summarizing the ANPR and wanted to provide some further thoughts and commentary on the ANPR.… Continue Reading

In February, the CFPB published its proposed rule defining larger participants in the debt collection and credit reporting industries. In general, the proposal advised that the CFPB would be guided by and would use a definition of annual receipts adapted from that used by the Small Business Administration in identifying small business concerns.… Continue Reading

The American Bar Association (ABA) and the Committee on Consumer Financial Services of the ABA’s Section of Business Law have submitted comment letters on two CFPB proposals. The Committee’s letter comments on the “larger participant” proposal and the ABA’s letter comments on the proposed rule on confidential treatment of privileged information.… Continue Reading

The official launch of the CFPB’s nonbank supervision program was the subject of a blog post by Peggy Twohig, the CFPB’s Associate Director for Nonbank Supervision, and Steve Antonakes, Associate Director for Large Bank Supervision. While much of the post rehashes comments made by Richard Cordray following his recess appointment as Director, a few items strike us as noteworthy.… Continue Reading

Now that it has a director, the CFPB will waste no time in beginning to exercise its authority to regulate mortgage originators and servicers and payday and student lenders. That’s the message Richard Corday began delivering yesterday following his appointment as CFPB Director. The Dodd-Frank Act gave the CFPB the authority to make rules for and examine these non-bank companies regardless of their size.… Continue Reading