Massive revisions to the Fair Debt Collection Practices Act (FDCPA), and its implementing Regulation F, have been unfolding over the past few years. The final rule is effective on November 30, 2021, although the CFPB has proposed to extend the effective date to January 29, 2022. Many banks want to operate under the assumption that the FDCPA and Regulation F do not apply to their operations. We have steadfastly maintained that the law and regulation
CFPB FINALIZES DELAY OF RECENT QM RULES
Category: CFPB, Qualified Mortgage, Regulation Z, Truth in Lending
On April 27, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule extending the mandatory compliance date of the General Qualified Mortgage (QM) Final Rule from July 1, 2021 to October 1, 2022. Additionally, the April 2021 Final Rule affects the expiration of the Temporary GSE QM loan definition or “Patch.” Under the April 2021 Final Rule, the Temporary GSE QM loan definition will expire on October 1, 2022 or the date the
CFPB INTERIM FINAL RULE REGARDING EVICTION MORATORIUM
Category: CFPB, Fair Debt Collection Practices Act, Regulation F
Nearly 9 million households are behind on their rental payments. Tens of thousands of renters are being evicted every week, often without being told of their rights under the CDC moratorium. As the CDC has found, tenants who are evicted may end up homeless or in crowded or shared living settings, increasing their vulnerability to COVID-19 and the risk of the disease spreading throughout communities. Such evictions can have long-term health, financial, and social consequences
CFPB SMALL ENTITY COMPLIANCE GUIDE FOR DEBT COLLECTION
Category: CFPB, Fair Debt Collection Practices Act, Regulation F
The CFPB has updated its Small Entity Compliance Guide for the Debt Collection Rule (Regulation F) to add the vastly expanded requirements of the December 2020 Final Rules. The CFPB recently issued a proposed revision to Regulation F to delay the effective date from November 30, 2021 to January 29, 2022.
On April 1, 2021, FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) requesting comments on new beneficial ownership reporting provisions included in the Corporate Transparency Act/Anti-Money Laundering Act of 2020, which was passed into law as part of the National Defense Authorization Act of 2021 on January 1, 2021. The ANPRM, published in the Federal Register on April 5, 2021, is requesting input on procedures and standards for reporting companies to submit information to
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