Archive

AGENCIES PROPOSE AMENDMENTS TO REGULATIONS CC AND DD

On November 21, 2018 the Bureau of Consumer Financial Protection (the Bureau) and the Federal Reserve Board (FRB), collectively the Agencies, proposed amendments to Regulation CC, the implementing regulation for the Expedited Funds Availability (EFA) Act, that would allow for adjustments in amount of funds depository institutions must make available to customers. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the EFA Act giving joint rulemaking authority to the Bureau and […]

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ATR/QM ASSESSMENT

The Dodd-Frank Act (DFA) requires the CFPB to review certain rules within five years after they take effect. The required reviews are called assessments. The CFPB is conducting an assessment of the ATR/QM rule, and will issue a report of the assessment by January 2019. As required by law, the assessment will address the rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act and the specific goals of the […]

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CFPB Takes Steps Toward Small Business Lending Data Collection Rules

The Consumer Financial Protection Bureau (CFPB) has begun to take steps toward implementing rules related to small business lending data collection. On May 10, 2017, the CFPB issued a Request for Information (RFI) regarding the small business lending market. This RFI coincides with a field hearing, on the same topic, set to take place later today in Los Angeles, California. Section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended […]

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IMPACT OF THE ELECTION

Following this week’s election we all need to evaluate the impact on our lives, families, and our businesses. Change is definitely coming, but will not happen overnight. If you have a positive view of the future I hope your vision comes true. If you are fearful of the future I hope your fears are unfounded. We need to closely watch the actions of Congress and the White House over the next few years to judge […]

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CFPB RELEASES PROPOSAL TO ELIMINATE PAYDAY DEBT TRAPS

As promised in the 2016 spring semi-annual agenda, the CFPB released today its proposal to end payday debt traps for consumers.  The proposed protections will cover those products that have developed a stigma of being harmful to consumers, including payday loans, auto-title loans, deposit advance products, and certain high-cost installment and open-end products.  While these may not be common products utilized in your financial institution, there may be a loan or two lurking on your […]

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