CFPB, Federal Agencies, State Agencies, and Attorneys General
The CFPB recently issued a request for information (RFI) on the Truth in Lending Act (TILA)/Real Estate Settlement Procedures Act (RESPA) Integrated Disclosure (TRID) rule, the right of rescission under TILA, and reverse mortgages. Comments are due by August 10, 2026.
The RFI is based on the March 2026 Executive Order (EO) 14393 entitled “Promoting Access to Mortgage Credit”.… Continue Reading
Although the Consumer Financial Protection Bureau under Acting Director Russell Vought has withdrawn from defending a number of Biden-era regulatory initiatives, the Bureau appears poised to revisit one of the most controversial issues in consumer credit regulation—credit card late fees.
According to the Office of Information and Regulatory Affairs (OIRA), the CFPB has submitted for interagency review a Request for Information (RFI) regarding “Credit Card Late Fees and Late Payments.”… Continue Reading
On July 25, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency (collectively, the agencies) issued a “Joint Statement on Banks’ Arrangements with Third Parties to Deliver Bank Deposit Products and Services” to “note potential risks related to arrangements between banks and third parties to deliver bank deposit products and services to end users”.… Continue Reading
The Consumer Financial Protection Bureau (CFPB), recently issued a Request for Information (RFI) related to fees charged by providers of mortgages and related settlement services. In his statement, Director Chopra discussed the impact of the increasing costs on lenders and consumers, and stated that the CFPB plans to address those costs.… Continue Reading
The Consumer Financial Protection Bureau (CFPB) issued a Request for Information (RFI) regarding employer-driven debt. Specifically, the CFPB is interested in “debt incurred to an employer or an associated entity, taken on in pursuit or in the course of employment.” Comments must be received by Wednesday September 7, 2022.
The CFPB is seeking input from all workers, including independent contractors and others who are not considered “employees” under the Fair Labor Standards Act.… Continue Reading
Ballard Spahr attorneys have submitted comments to the CFPB in response to its Request for Information Regarding Bureau Rules of Practice for Adjudication Proceedings.
Our comments are based on the extensive experience of Ballard Spahr attorneys in representing bank and non-bank clients in connection with more than 50 CFPB investigations. … Continue Reading
The CFPB has issued a request for information that seeks comment on its handling of consumer complaints and inquiries. Comments on the RFI must be received by July 16, 2018.
The CFPB defines consumer complaints as “submissions that express dissatisfaction with, or communicate suspicion of wrongful conduct by, an identifiable entity related to a consumer’s personal experience with a financial product or service.” … Continue Reading
We believe the CFPB’s recent RFI on the Bureau’s adopted regulations, which Acting Director Mulvaney discussed during his testimony before the House Financial Services and Senate Banking Committees, provides the prepaid industry an opportunity to persuade the Bureau to reconsider its prepaid rule that was issued in October 2016 and amended in January 2018.… Continue Reading
The CFPB has issued a request for information that seeks comment on its consumer financial education programs. Comments on the RFI must be received by July 9, 2018.
The CFPB seeks feedback on all aspects of its consumer financial education programs, including the following topics:
In response to the CFPB’s question asking what financial education topics it should address, we would suggest that the CFPB educate consumers about arbitration, something it has not previously done.… Continue Reading
The CFPB has issued a request for information that seeks comment on its guidance and implementation support. Comments on the RFI must be received by July 2, 2018.
The RFI lists the following areas of interest on which commenters may want to focus input:
