Archive

CFPB REQUESTS INFORMATION ON OVERDRAFT PROGRAMS

The Consumer Financial Protection Bureau (CFPB) has published a Notice and Request for Information on overdraft programs. The Dodd-Frank Act grants regulatory authority to the CFPB for the Electronic Funds Transfer Act and the Truth in Savings Act, which taken together, in part, govern consumer transaction accounts. The CFPB is reviewing existing regulations and supervisory guidance issued by various regulators pertaining to the use of overdraft programs by financial institutions. To support this review, the […]

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LOAN ORIGINATOR COMPENSATION RULES

The rules, which were effective April 1, 2011, restrict the methods available to compensate mortgage loan originators. The rules are confusing. Interpretations are lacking. The rules were issued by the Federal Reserve Board, but then in July authority for Regulation Z transferred from the Federal Reserve to the Consumer Financial Protection Bureau (CFPB). The CFPB has not issued any interpretations for the regulations it inherited from the the agencies. But issues and questions persist, especially […]

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CFPB CONSUMER ADVISORY BOARD

The Dodd-Frank Wall Street Reform and Consumer Protection Act requires the Consumer Financial Protection Bureau (CFPB) to set up the Consumer Advisory Board (CAB). CAB members will provide the CFPB with information about emerging trends and practices in the financial-services and financial-products industries. The CFPB is seeking members with diverse perspectives and innovative ideas. Nominees may have a background in one or more of the following areas: consumer protection, financial services, fair lending, civil rights, […]

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HMDA THRESHOLD – BETTER LATE THAN NEVER

Today the Consumer Financial Protection Bureau (CFPB) published the HMDA asset threshold. The exemption threshold has been adjusted to $41 million from $40 million. The adjustment is based on the 3.43 percent increase in the average of the CPI-W for the twelve-month period ending in November 2011. Therefore, depository institutions with assets of $41 million or less as of December 31, 2011 are exempt from collecting HMDA data in 2012. Remember, HMDA was previously implemented […]

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NEW MONTHLY STATEMENTS FOR MORTGAGE LOANS

The next chapter in the future of mortgage lending was published by the Consumer Financial Protection Bureau (CFPB) this week. As required by the Dodd-Frank mortgage lenders and related parties soon will be required to give borrowers with closed-end mortgage loans a statement for each billing cycle. Many financial institutions already provide statements. Currently there is no standard format for statements. Section 1420 of the Dodd-Frank Act amends the Truth in Lending Act by requiring […]

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