Links in “CFPB”
- Et Tu FCA? Apparently, Yes
Farm Credit Administration will be handing over S.A.F.E. Act oversight to CFPB with recoding of regulation to include FCA. [8/20]
- Two-Year Transition Period for Balloon-Payment Qualified Mortgages
In its final rule, CFPB adopted a two-year transition period during which all small creditors can make balloon-payment QMs, even if they do not operate predominantly in rural or underserved areas; here are more details. [8/19]
- Mortgage Rules Round 2: Debt Ratios Cannot Be Based on Teaser Rates
Lenders cannot base a borrower's DTI ratio on teaser rates and must show that the borrower can repay the loan over the long term, not just during an introductory period where the rate is lower. Other clarifications also provided in CFPB's second round of mortgage rule guidance. [8/16]
- CFPB to Provide Guidance on Rules Through Enforcement?
Conference attendees struggle to get clarity on rules from CFPB officials, most of whom are from the enforcement side, rather than the policy-making side. [8/16]
- CFPB Seeks Quick Revision to Privacy Act for Use of Social Media
Proposal (comments due 9/16/2013) seeks to expand use and distribution of social media information obtained by CFPB from tweets, facebook, etc. Distribution partners include not so surprisingly the DOJ among others. [8/16]
- CFPB Awakes and Publishes 2nd Round of Lending Best Practices
2nd update to "Best Practices" for Mortgage and other lending programs shows direction FIs must pursue to stay ahead of regulatory curve. Policy and procedural "guidance" offered. [8/16]
- “Small Servicers” Exemption to Mortgage Rules Clarified
A look at the CFPB's recently published clarification of the "small servicers" exemption. [8/15]
- Dog Days of Summer? Calm Before the Storm?
Perhaps you too have noticed that over the past three weeks (7/23 to now 8/14) the CFPB has not issued a single press release. This marks (by far) the longest gap for a press release in quite some time (September 2011). What does it all mean? [8/14]
- CFPB’s Proposal to Survey Credit Card Customers on Arbitration Awareness Draws Industry Fire
Several industry and other business groups decry CFPB's proposal to undertake a telephone survey of 1,000 credit card holders to ascertain their understanding regarding the arbitration provisions in their contracts; effort seen as leading to rulemaking on flawed findings. [8/14]
- When the Sniff Test Just Won’t Do: CFPB Gives UDAAP Examples
Sometimes the "if you think you have a UDAAP problem, you do" sniff test doesn't quite cut it; CFPB releases bulletin giving potential examples of unfair, deceptive and/or abusive acts or practices. [8/14]
