Last Friday in New Orleans, the ABA Business Law Section Consumer Financial Services Committee hosted a fascinating program about CFPB enforcement at the Section’s 2017 Spring Meeting. The program was entitled: “Too Much or Too Little? Is the CFPB Exercising its Enforcement Power with Appropriate Restraint?” As might be expected, the two industry representatives on the panel criticized certain of the CFPB’s enforcement initiatives, including, among others, the PHH case and the use of disparate impact analysis in connection with discretionary dealer pricing to assess Equal Credit Opportunity Act (“ECOA”) compliance by auto finance companies. … Continue Reading
Regulation B
CFPB proposes alignment of Regulation B and Regulation C requirements regarding collection of consumer ethnicity and race information
By Ballard CFS Group on
Posted in CFPB Rulemaking, Regulatory and Enforcement
On March 24, the CFPB announced a proposal to amend Regulation B requirements related to the collection of consumer ethnicity and race information, in order to resolve the differences between Regulation B and revised Regulation C. These proposed rule amendments are effective on January 1, 2018, the same effective date as the 2015 Home Mortgage Disclosure Act (HMDA) Final Rule.… Continue Reading