CFPB, Federal Agencies, State Agencies, and Attorneys General
The New York City Department of Consumer Affairs (DCA) has adopted new rules for used car dealers, requiring all licensed dealers to make additional disclosures to consumers and creating a new consumer bill of rights for the industry. The new rules went into effect on June 24, 2018.
Under the new rules, dealers must provide a financing statement in a prescribed form prior to the execution of any retail installment contract (RIC). … Continue Reading
Last week, members of the Senate Banking Committee announced that they had reached bipartisan agreement on “legislative proposals to improve our nation’s financial regulatory framework and promote economic growth.” Following the announcement, Committee members released a draft of a bill (S. 2155), the “Economic Growth, Regulatory Relief, and Consumer Protection Act.” … Continue Reading
The CFPB, Fed, and OCC have published notices in the Federal Register announcing that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2018 through December 31, 2018, these exemption thresholds are increased as follows:
The CFPB recently released a revised version of the TILA-RESPA Integrated Disclosure Rule Small Entity Compliance Guide.
The revised version incorporates the recent amendments to the rule that became effective on October 10, 2017. Compliance with the amendments will be required for applications received on or after October 1, 2018.
The amendments also clarified that the separate escrow cancellation notice and partial payment disclosure requirements under Regulation Z will apply to all covered loans on October 1, 2018, regardless of when the application is received.… Continue Reading
On August 21, 2017, the Office of the Comptroller of the Currency (OCC) published Bulletin 2017-28 regarding higher-loan-to-value (LTV) lending programs (the “Bulletin”). Recognizing the need for further revitalization efforts in distressed communities, the Bulletin addresses how banks may establish mortgage lending programs for loans to finance the purchase, or the purchase and rehabilitation, of one-to four-unit residential properties located in certain communities when the LTV ratio at origination exceeds 100 percent.… Continue Reading
The Federal Trade Commission has provided its annual Financial Acts Enforcement Report to the CFPB covering the FTC’s enforcement activities in 2016 relating to compliance with Regulation Z (Truth in Lending Act), Regulation M (Consumer Leasing Act), and Regulation E (Electronic Fund Transfer Act). Under Dodd-Frank, the FTC retained its authority to enforce these regulations with respect to entities subject to its jurisdiction. … Continue Reading
The CFPB announced that it filed a lawsuit in a Virginia federal district court against B&B Pawnbrokers, Inc., for alleged violations of the Truth in Lending Act and the Consumer Financial Protection Act in connection with closed-end consumer loans made by the company. While the complaint only describes the loans as closed-end loans secured by personal property, the CFPB’s press release describes the loans as “pawn and auto title loans.”… Continue Reading
The CFPB announced that it has filed administrative enforcement actions against five Arizona auto title lenders for alleged violations of Truth in Lending Act advertising requirements. According to the CFPB, the lenders violated TILA by advertising a periodic interest rate for their loans on their websites without advertising a corresponding annual percentage rate. … Continue Reading
The CFPB filed suit against J.G. Wentworth, LLC on June 7, 2016 after the company challenged the Bureau’s expansive view of its jurisdiction.
The CFPB served a CID against J.G. Wentworth, LLC on September 11, 2015 to investigate alleged violations of consumer protection laws. J.G. Wentworth purchases structured settlements and annuities from consumers for lump sums.… Continue Reading
The CFPB recently published a fact sheet for small creditors operating in rural or underserved areas. As we have reported, the CFPB issued a final rule, which became effective on January 1, 2016, revising the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA).… Continue Reading
