Barbara S. Mishkin

Barbara S. Mishkin

Ballard Spahr LLP

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ABA seeks removal of mortgage rate calculator from CFPB website

The American Bankers Association has sent a letter to the CFPB urging it to take down from its website its new mortgage interest rate calculator tool. The CFPB launched the new tool earlier this month, in conjunction with its...more

1/30/2015 - American Bankers Association Banks CFPB Interest Rates Mortgage Lenders Mortgages

CFPB issues compliance bulletin on treatment of confidential supervisory information

In a new compliance bulletin (2015-01), the CFPB reminds supervised financial institutions, including nonbanks, of their obligations regarding the disclosure of confidential supervisory information (CSI)....more

1/29/2015 - Banking Sector Banks CFPB Confidential Information Disclosure Requirements Financial Institutions Nonbank Firms Supervision

CFPB issues report on financial well-being

A new CFPB report entitled “Financial well-being: The goal of financial education” describes the CFPB’s initial research into how people acquire financial capability. The CFPB states in the report that it undertook the...more

1/29/2015 - CFPB Financial Education Initiatives

Financial Services Roundtable and CFPB join forces in financial education initiative

The Financial Services Roundtable and CFPB are joining forces in a nationwide public-private initiative to promote effective financial education. According to an announcement posted on the Roundtable’s website, the CFPB and...more

1/29/2015 - CFPB Financial Education Initiatives

Update on state AGs/regulator lawsuits using Dodd-Frank authority

Below is an update on the lawsuits we have been following that state attorneys general and a state regulator have brought using their Dodd-Frank enforcement authority. Under Dodd-Frank Section 1042, a state AG or regulator is...more

1/28/2015 - Automotive Loans CFPA Consumer Lenders Dodd-Frank Enforcement Actions Experian For Profit Colleges Popular Subprime Mortgages TILA UDAAP Unfair Trade Practices Act

CFPB announces leadership additions and changes

Last Friday, the CFPB announced the following additions to its senior leadership team: In its announcement, the CFPB confirmed that Anthony Alexis will become the CFPB’s Assistant Director of Enforcement. Mr. Alexis...more

1/26/2015 - CFPB Political Appointments

House Financial Services Committee approves oversight plan; Committee chair gets new subpoena authority

The House Financial Services Committee voted unanimously today to approve the Committee’s oversight plan for the 114th Congress. The plan provides that the Committee intends to continue its close examination of the...more

1/22/2015 - Amended Regulation CFPB Choke Point Consumer Financial Products Dodd-Frank Financial Services Committee Mortgages

ABA criticizes CFPB study on high-cost credit extended to servicemembers

The American Bankers Association has sent a letter to the Department of Defense “to alert the Department to shortcomings” in the CFPB’s study entitled “The extension of high-cost credit to servicemembers and their families”...more

1/22/2015 - American Bankers Association Banks CFPB DOD Military Lending Act Military Service Members

CFPB seeking new members for advisory groups

The CFPB has published a notice in the Federal Register announcing that it is seeking applications from persons interested in becoming members of its Consumer Advisory Board, Community Bank Advisory Council, or Credit Union...more

1/19/2015 - Administrative Appointments CFPB Community Banks Consumer Advisory Board

ABA urges OIG to expand scope of consumer complaint database audit

The American Bankers Association (ABA) has sent a letter to the Office of the Inspector General (OIG) urging it to expand two of its ongoing CFPB projects: an audit of the CFPB’s public consumer complaint database and a...more

1/16/2015 - American Bankers Association Audits CFPB Consumer Complaint System OIG

CFPB attorney addresses impact of CFPB expectations on existing service provider contracts

Peggy Twohig, the CFPB’s Assistant Director for Nonbank Supervision, was a member of a panel today on service provider and vendor management compliance issues at this week’s meeting in New Orleans of the American Bar...more

1/12/2015 - Bank Service Providers Banks CFPB Enforcement Actions Nonbank Firms

CFPB plans to launch financial education project for disabled individuals

The CFPB continues to seek comments on its plans to launch in the winter of 2015 what it describes as “a multi-site financial education demonstration project to provide one-on-one and group financial counseling/coaching...more

1/9/2015 - CFPB Disabled Financial Education Initiatives

CFPB makes two leadership changes

According to the Wall Street Journal, the CFPB is making two changes in leadership. Tony Alexis, who previously served as Deputy Director of Enforcement Field Litigation and is currently serving as Acting Director of...more

1/8/2015 - Administrative Appointments CFPB

CFPB issues second appropriations report

The CFPB has issued its second report entitled “Report of the Consumer Financial Protection Bureau Pursuant to Section 1017(e)(4) of the Dodd-Frank Act.” That Dodd-Frank section requires the CFPB’s Director to submit an...more

1/6/2015 - Annual Reports Appropriation CFPB Dodd-Frank

CFPB adjusts HMDA/TILA asset-size exemption thresholds

Adjustments to two asset-size exemption thresholds were published by the CFPB in today’s Federal Register. First, the CFPB has increased the asset-size exemption threshold under HMDA/Regulation C which is currently set at $43...more

12/29/2014 - Banks CFPB Credit Unions Exemptions HMDA TILA

NY regulator settles lawsuit filed using Dodd-Frank authority

A settlement has been announced in the lawsuit filed by Benjamin Lawsky, the Superintendent of the New York Department of Financial Services, using his Dodd-Frank Section 1042 authority. Section 1042 allows state attorneys...more

12/24/2014 - Automotive Industry Automotive Loans Civil Monetary Penalty Consent Order Dodd-Frank TILA Unfair or Deceptive Trade Practices

Banking industry trade groups comment on Defense Department’s proposed amended MLA regulations

The American Bankers Association, Consumers Bankers Association, Independent Community Bankers of America, National Association of Federal Credit Unions, and Association of Military Banks of America have submitted a 59-page...more

12/23/2014 - American Bankers Association Banking Sector Banks DOD Military Lending Act Trade Associations

CFPB settles with military base retailer and related companies for alleged unlawful debt collection practices

As part of this week’s flurry of enforcement-related announcements, the CFPB announced the settlement of a lawsuit filed jointly with the Attorneys General of North Carolina and Virginia against Freedom Stores, Inc....more

12/22/2014 - CFPB Consent Order Debt Collection Dodd-Frank Enforcement Actions Internet Retailers Popular Retailers UDAAP

Banking trade groups comment on CFPB’s proposed no-action letter policy

The American Bankers Association, American Bankers Insurance Association and Consumers Banking Association have submitted a joint comment letter on the CFPB’s proposed policy on issuing “no-action” letters for innovative...more

12/19/2014 - Banking Sector Banks CFPB No-Action Letters

CFPB sues company for alleged credit card sham

A new lawsuit filed by the CFPB alleges that a Texas-based company, Union Workers Credit Services, deceived consumers into paying fees to sign up for a “platinum card” that purported to be a general-use credit card but, in...more

12/18/2014 - CFPB Credit Cards Enforcement Actions FCRA Regulation V

CFPB sues company for alleged credit card sham

A new lawsuit filed by the CFPB alleges that a Texas-based company, Union Workers Credit Services, deceived consumers into paying fees to sign up for a “platinum card” that purported to be a general-use credit card but, in...more

12/18/2014 - CFPB Credit Cards Enforcement Actions FCRA Regulation V Unfair or Deceptive Trade Practices

CFPB announces pilot to promote consumer savings

As part of its Project Catalyst, the CFPB’s initiative for facilitating innovation in consumer-friendly financial products and services, the CFPB has announced a new research pilot using insights from behavioral economics and...more

12/17/2014 - American Express CFPB Consumer Financial Products Credit Cards Financial Products Prepaid Payment Products Project Catalyst Savings Plans

CFPB announces lawsuits against student loan debt relief companies

On December 11, the CFPB announced lawsuits against two student loan debt relief companies alleged to have deceived borrowers into paying upfront fees for federal student loan repayment benefits that are available for free....more

12/15/2014 - CFPB Debt Collectors Debt-Relief Industry Enforcement Actions Federal Student Loans Student Loans

CFPB’s proposed boarding form for online consumer complaint company portal now available

Last week, the CFPB published a Federal Register notice stating that it was developing a form to allow companies to “proactively participate” in its online company portal for viewing and responding to consumer complaints....more

12/12/2014 - CFPB Consumer Complaint System

Director Cordray provides update on CFPB’s public library partnerships

In his remarks last week at the Columbus Metropolitan Library, Director Cordray spoke about the partnerships that the CFPB is building with public libraries around the country to promote accessible financial education...more

12/11/2014 - CFPB Libraries P3s Public-Private Partnerships Richard Cordray

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