CFPB, Federal Agencies, State Agencies, and Attorneys General
Last December, when the CFPB issued its prototype credit card agreement, the CFPB announced that Pentagon Federal Credit Union had signed up to test the prototype with its customers.
According to a notice published yesterday by the CFPB in the Federal Register, Pentagon is launching a testing program this fall of a “short-form credit card agreement” which it will be sending to new cardholders in the fourth quarter of 2012 and the first quarter of 2013. … Continue Reading
The CFPB now wants comments on a prototype monthly mortgage statement. The form already has been through one round of testing, and two more rounds are planned.
Despite industry opposition, the Dodd-Frank Act included a requirement for creditors, assignees or servicers of mortgage loans to provide periodic statements to borrowers containing specified information and directed the CFPB to develop a model form for the statements that takes into account the possibility of either written or electronic delivery.… Continue Reading
The CFPB has launched a third round of testing in its “Know Before You Owe” project. Last month, as we reported, the CFPB began testing and requested public input on two revised prototypes (named Mimosa and Sassafras) of a mortgage loan settlement disclosure combining the final TILA disclosure and the RESPA HUD-1 Settlement Statement.… Continue Reading
Last month, as part of its “Know Before You Owe project,” the CFPB began taking comments on two prototypes (named Hornbeam and Ironwood) of a settlement disclosure that combines the final TILA disclosure and the RESPA HUD-1 Settlement Statement. The CFPB received over 3,000 comments on the prototypes. This week, based on those comments, the CFPB posted two new prototypes (named Mimosa and Sassafras) on its website which it will be testing in Birmingham, Alabama and on which it is requesting public input.… Continue Reading
I share much of Chris’ reaction to the Bureau’s prototype cardholder agreement. The Bureau staff has labored mightily and has managed to produce an agreement that is six-(not two) pages of material. In considering the Bureau’s success or lack of success in producing a short cardholder agreement, it is important to note that the Bureau’s draft utterly fails to comply with the increasingly elaborate and complex regulatory requirements that have contributed greatly over the years to the length and complexity of cardholder agreements.… Continue Reading
On December 7, 2011, the CFPB released its “prototype” credit card agreement, cautioning that it is “not a model form” and that its use is “not mandatory.” Although the prototype agreement is being referred to as a “2-page agreement,” it incorporates a series of definitions by reference that comprise a further 4 pages of text. … Continue Reading
