Archive

RURAL REMINDERS

2019 list of rural and underserved counties The Consumer Financial Protection Bureau (CFPB) has published the 2019 list of rural and underserved counties and a separate 2019 list that includes only rural counties. The CFPB has also updated the Rural and Underserved Areas Tool (Tool) for 2019. The lists and the tool help creditors determine whether a property is located in a rural or underserved area for purposes of applying certain regulatory provisions related to mortgage loans. […]

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CFPB ISSUES PROPOSAL TO DELAY AND RESCIND PAYDAY LENDING UNDERWRITING RULES

On February 6, 2019 the Consumer Financial Protection Bureau issued two notices of proposed rulemaking (NPRM) related to the Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (2017 Payday Lending Rule). As finalized, the 2017 Payday Lending Rule has two primary parts: 1) Subject to certain exceptions, for short-term and longer-term loans with balloon payments, it is unfair and abusive for a lender to make such loans without determining that consumers have the ability […]

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CFPB ISSUES TRID GUIDANCE

On January 25, 2019 the Consumer Financial Protection Bureau released four Frequently Asked Questions (FAQs) Related to TRID. The first three questions deal with corrected disclosures and the three-day waiting period before closing. The final questions involves a form issue. The questions and answers are available below and by clicking here. If there is a change to the disclosed terms after the creditor provides the initial Closing Disclosure, is the creditor required to ensure the […]

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MILITARY LENDING ISSUES

What’s going on with military lending? Is there a pattern we should be watching? On January 17, 2019 the Consumer Financial Protection Bureau (CFPB) announced that it has asked Congress to grant the agency clear authority to supervise for compliance with the Military Lending Act (MLA). On January 24, 2019 the CFPB announceda settlement a broker of contracts offering high-interest credit to veterans. The Consent Order filed by the CFPB states that the Bureau found the […]

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WHERE IS THE CFPB HEADED? UPDATE

Last week we reported that the CFPB has its first Director, not Acting Director, since Richard Cordray resigned a little over a year ago. We observed that due to lack of meaningful prior experience it is difficult to predict the direction in which Director Kathy Kraninger might steer the agency. She appears to be starting out with a few lightweight items. For example, under Director Cordray the agency was the Consumer Financial Protection Bureau. Acting […]

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