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THE CFPB INHERITS REGULATION DD

Congress enacted the Truth in Savings Act (TISA), 12 U.S.C. 4301, based on findings that economic stability would be enhanced, competition between depository institutions would be improved, and consumers’ ability to make informed decisions regarding deposit accounts would be strengthened if there was uniformity in the disclosure of interest rates and fees. The purpose of the act and regulation is to assist consumers in comparing deposit accounts offered by depository institutions, principally through the disclosure of […]

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STATUS OF CFPB’s COMBINED MORTGAGE DISCLOSURES

Several months ago, the Consumer Financial Protection Bureau (CFPB) published in its blog two sample closing disclosures that combine final Truth in Lending (TIL) disclosures with HUD-1 disclosures. They requested that consumers and industry members compare two prototypes for the disclosures and vote on the preferred option. Now the CFPB is asking consumers and industry members to look specifically at how the new closing disclosure prototypes work with the application disclosure prototype, which was pretty […]

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CFPB FOCUSES ON SHORT-TERM, SMALL-DOLLAR LENDING

On January 19th, the Consumer Financial Protection Bureau (CFPB) published Short-Term, Small-Dollar Lending (STSD) Procedures – a field guide CFPB examiners will use to make sure payday lenders are following federal consumer financial laws. The procedures are applied to both banks and nonbanks that make payday loans. This development is significant for two reasons: The payday lending market has not been largely unregulated. Now participants in the market will undergo a federal examination. The STSD […]

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THE CFPB INHERITS REGULATION Z

Congress enacted the Truth in Lending Act (TILA) in 1968 based on findings that the informed use of credit resulting from consumers’ awareness of the cost of credit would enhance economic stability and would strengthen competition among consumer credit providers. One of the purposes of TILA is to provide meaningful disclosure of credit terms to enable consumers to compare credit terms available in the marketplace more readily and avoid the uninformed use of credit. TILA […]

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CFPB RELEASES MORTGAGE ORIGINATION EXAMINATION PROCEDURES

The Consumer Financial Protection Bureau (CFPB) recently announced a key initial step in implementing its Nonbank Supervision program — the publication of the Mortgage Origination Examination Procedures (MOEP). The procedures are a field guide for CFPB examiners looking at mortgage originators in both the bank and nonbank sectors of the industry. The procedures are significant for two reasons: A lightly regulated segment of the mortgage market – independent lenders, brokers, servicers, and others unaffiliated with […]

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