MOST RECENT CFPB SEMI-ANNUAL RULEMAKING AGENDA

Recently the Consumer Financial Protection Bureau (CFPB) published its most recent semiannual rulemaking agenda. There were no big surprises in the agenda. This article reviews three issues of concern.

Integrated Disclosures and Finance Charge Rules – The biggest rules yet to be finalized are the new integrated disclosures. The disclosures include the loan estimate (that combines the early TIL disclosure and the good faith estimate) and the closing disclosure (that combines the final TIL disclosures and the HUD-1). Revised finance charge rules are also expected as part of the final rule. Previously the CFPB has promised the final rules by September 2013. The latest agenda delays those disclosures until October 2013.

Additional HMDA Data Collection – The Dodd-Frank Act significantly expands the HMDA Loan Application Register to include additional data on pricing, underwriting and other topics. The agenda indicates that the next action, which should be proposed regulations, are expected in September 2013.

New ECOA Business Loan Data Collection – The Dodd-Frank Act expanded the Equal Credit Opportunity Act to require the collection of HMDA-like data for business loans. The law contained an effective date of July 21, 2011. In May 2011 the CFPB announced that the rule would not be completed by the mandated effective date, but the rule was a high priority for the CFPB. In every semi-annual since then the rule has been pushed off further into the future. Now it is not even on the agenda. So much for high priorities.

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