Auriemma Roundtables, a leading provider of business intelligence solutions to the consumer finance industry, together with First National Bank of Omaha and a group of several other premier consumer financial services firms, has filed a comment (the “Auriemma Roundtables Comment”) on the credit card penalty fees proposal (the “Proposed Rule”) issued by the Consumer Financial Protection Bureau (CFPB). … Continue Reading
penalty fee
CFPB publishes annual CARD Act, HOEPA and QM adjustments, corrects 2016 error
By Brian Slagle on
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments reflect changes in the Consumer Price Index in effect on June 1, 2016 and will take effect January 1, 2017.… Continue Reading
CFPB publishes annual CARD Act, HOEPA and QM adjustments
By Barbara S. Mishkin on
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments made by the final rule are effective January 1, 2016.
The CARD Act requires the CFPB to calculate annual adjustments of (1) the minimum interest charge threshold that triggers disclosure of the minimum interest charge in credit card applications, solicitations and account opening disclosures, and (2) the fee thresholds for the penalty fees safe harbor. … Continue Reading