Archive

CFPB ISSUES HPML ESCROW EXEMPTION

On January 19. 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending section 1026.35 of Regulation Z to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). The rule will take effect on publication in the Federal Register. It exempts from the HPML escrow […]

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CFPB Advisory Opinion on Special Purpose Credit Program

On December 21, 2020, the Consumer Financial Protection Bureau published an Advisory Opinion (AO) on Special Purpose Credit Programs established per the requirements of the Equal Credit Opportunity Act and Regulation B. It is designed to address regulatory uncertainty in special purpose credit programs designed and implemented by for-profit organizations to meet special social needs. Specifically, this AO clarifies: The content that a for-profit organization must include in a written plan that establishes and administers […]

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Final Final Fair Debt Collections Practices Act is Published

On December 18, 2020, the Consumer Financial Protection Bureau (CFPB) released the second part of its final rule, Regulation F, which implements the Fair Debt Collection Practices Act. The first part of the final rule was published on October 30, 2020. The most recent release has three primary components dealing with validation notices, passive debt collection through negative reporting, and the collection of time-barred debt.  Most notably, the provisions dealing with time-barred debt depart significantly […]

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CFPB ISSUES TWO QM RULES

On December 10, 2020, the Consumer Financial Protection Bureau (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Rule, replaces the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43 percent with a limit based on the loan’s pricing. The second final rule, reveals a new Seasoned QM. General QM – Under the final rule a loan receives a conclusive […]

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CFPB ADVISORY OPINIONS

On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) issued its Advisory Opinions Policy, which sets forth procedures to facilitate the submission by interested parties of requests that the CFPB issue advisory opinions, in the form of interpretive rules, to resolve regulatory uncertainty, and the manner in which the Bureau will evaluate and respond to such requests. The CFPB also released its first Advisory Opinions that clarify the following Regulation Z issues: Private Education […]

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