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Last week, the CFPB released its most recent update to the Prepaid Rule Small Entity Compliance Guide.  The new version includes expanded information regarding the process for complying with the Prepaid Rule’s requirement to submit prepaid account agreements and certain other information to the CFPB.

Under the Prepaid Rule, prepaid issuers must make submissions to the CFPB on a rolling basis, including new prepaid accounts agreements and updates to reflect changes to existing agreements submitted in the past. … Continue Reading

The CFPB has issued a new small entity compliance guide: “Payday, Vehicle Title and High-Cost Installment Lending Rule: Payment-Related Provisions.”

The CFPB has proposed to revise its final payday/auto title/high-rate installment loan rule to rescind the rule’s ability-to-repay (ATR) provisions in their entirety and to delay the compliance date for the ATR provisions until November 19, 2020. … Continue Reading

The CFPB recently issued an 89-page small entity compliance guide for the TILA-RESPA Integrated Disclosure Rule (the “Guide”).  As we reported previously, the CFPB issued the final rule in November 2013 to integrate the initial and final mortgage loan disclosures under the Truth in Lending Act and RESPA.  The final rule appeared in the December 31, 2013 Federal Register, and the rule becomes effective August 1, 2015. … Continue Reading

On August 14th, the CFPB released an update to the Small Entity Compliance Guide for the Ability-to-Repay and Qualified Mortgage Rule, incorporating the changes made in the June 2013 Concurrent Final Rule and July 2013 Final Rule. The updated guide includes a new section detailing the exemptions added by the June 2013 Concurrent Final Rule for certain creditors and loan programs, such as designated community development organizations, certain nonprofit organizations, and loans made pursuant to housing finance agency programs.… Continue Reading

The CFPB has issued two more Small Entity Compliance Guides on its mortgage-related rules.  The latest guides cover the mortgage servicing rule and loan originator compensation rule finalized by the CFPB in January 2013. 

As did the CFPB’s previously-released guides, the new guides caution that they are not substitutes for the underlying rules.… Continue Reading