Two notices with requests for comments recently published by the CFPB present prime opportunities for banks and other regulated institutions to engage with the CFPB not only to positively impact the CFPB’s processes and procedures, but also to demonstrate that banks seek to develop a relationship of cooperation and collaboration with the CFPB.… Continue Reading
In my post dated August 8, 2011, I took the CFPB to task for saying in its recent Progress report that it had entered into a MOU with the FTC when it had not done so according to Joel Winston, Associate Director of the Division of Financial Practices. I recently learned that the CFPB has entered into a MOU with the FTC, HUD, and DOJ regarding fair lending issues, but that it has not entered into a MOU with the FTC covering broader enforcement issues. … Continue Reading
Dodd-Frank’s definition of “financial product or service” clarifies that those offering public records information retrieval or fraud prevention services are not only outside the reach of the Bureau, but also not subject to the FCRA.