Barbara S. Mishkin

Barbara S. Mishkin

Ballard Spahr LLP

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CFPB issues FY 2014 financial report; GAO finds material weakness in CFPB reporting controls

The CFPB has issued its financial report for its 2014 fiscal year, which ended on September 30, 2014. Perhaps most illustrative of the CFPB’s growth are the report’s statistics on the CFPB’s employees and funding. The report...more

11/21/2014 - Accounting Controls Audit Reports CFPB Financial Reporting GAO

OIG updated work plan includes evaluations of CFPB enforcement-related processes and procedures

The Office of Inspector General’s (OIG) work plan, updated as of November 7, 2014, indicates that the OIG’s ongoing projects include audits of the CFPB’s information security program, pay and compensation program,...more

11/21/2014 - Audits CFPB OIG Policies and Procedures Work Plans

CFPB issues prepaid account study

Simultaneously with the release of its 870-page prepaid account proposal last week, the CFPB issued a “Study of prepaid account agreements.” On December 12, 2014, from 12 p.m. to 1 p.m. ET, Ballard Spahr attorneys will hold a...more

11/18/2014 - CFPB Prepaid Payment Products Regulation E

A further update on state AG/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

11/13/2014 - Compliance Dodd-Frank Enforcement Enforcement Actions Title X UDAAP

CBO provides cost estimate for bill to reform CFPB’s inspector general

The Congressional Budget Office has issued an estimate of the costs associated with the Inspector General Reform Act of 2013 (H.R. 3770). The bill would direct the President to appoint an Inspector General (IG) for the CFPB...more

11/7/2014 - CFPB Congressional Budget Office Funding Inspector General

OIG identifies five major CFPB management challenges

The joint Federal Reserve/CFPB Office of the Inspector General (OIG) recently issued its first listing of “major management challenges” facing the CFPB. These challenges represent what the OIG believes to be “the areas that,...more

11/4/2014 - Audits CFPB Compliance Enforcement OIG

CFPB highlights unlawful practices relating to mortgage and student loan servicing, debt collection, electronic fund transfers and...

While mortgage and student loan servicing violations cited by the CFPB in its Fall 2014 Supervisory Highlights have grabbed the headlines, the report also includes noteworthy observations regarding the violations found by the...more

10/31/2014 - CFPB Debt Collection Electronic Payment Transactions FDCPA Loan Servicer Mortgage Servicers Student Loans

Mortgage company that entered into CFPB consent order moves to dismiss class action claims

Earlier this week, Castle & Cooke Mortgage, LLC, the mortgage company that entered into a consent order with the CFPB in November 2013 to settle charges that it violated the Regulation Z loan originator compensation rule (“LO...more

10/31/2014 - CFPB Class Action Consent Order Mortgages Motion to Dismiss

CFPB announces November 13 “mystery” field hearing

Departing from its past practice, the CFPB has announced that it will hold a field hearing in Wilmington, Delaware on November 13 but has not yet disclosed what the hearing will be about. Instead, the announcement says only...more

10/30/2014 - Administrative Hearings CFPB Richard Cordray

Defendants file appeal in NY regulator’s lawsuit using Dodd-Frank authority

The defendants in the lawsuit brought by Benjamin Lawsky, the Superintendent of the New York Department of Financial Services, using his Dodd-Frank enforcement authority have filed an appeal with the U.S. Court of Appeals for...more

10/24/2014 - Appeals Cross-Complaints Dodd-Frank Enforcement Actions Unfair or Deceptive Trade Practices

Senator Crapo seeks information on CFPB’s regulatory streamlining efforts

In our blog post yesterday about the CFPB’s final rule allowing an alternative online delivery method for annual privacy notices, we commented that the CFPB has made limited progress on its regulatory streamlining initiative...more

10/24/2014 - Annual Notices CFPB Final Rules Legislative Committees Richard Cordray

CFPB issues final rule allowing alternative online delivery method for annual privacy notices

Nearly three years after identifying the Gramm-Leach-Bliley Act (GLBA) annual privacy notice requirement as a candidate for streamlining, the CFPB issued a final rule earlier this week to allow financial institutions that...more

10/23/2014 - Annual Notices Banking Sector CFPB Final Rules Financial Institutions Gramm-Leach-Blilely Act Notice Requirements

CFPB manufactured housing white paper may presage future regulation

The CFPB has issued a white paper on the manufactured housing market, including how manufactured housing is financed and the types of consumers who purchase or rent such housing. In the paper’s introduction, the CFPB explains...more

10/2/2014 - Affordable Housing CFPB Manufactured Housing

CFPB seeks organizations to host financial coaches

In July 2013, the CFPB announced its plans to launch a financial coaching project in 2014 for transitioning veterans and economically vulnerable consumers. Last week, the CFPB announced that it has contracted with the Armed...more

10/2/2014 - CFPB Financial Education Initiatives Veterans

CFPB seeking approval for field study of Owning a Home project

The CFPB has published a notice stating that as part of its Owning a Home project, it plans to seek approval from the Office of Management and Budget to conduct a field study of the project. The project consists of a various...more

9/30/2014 - CFPB Mortgages OMB Research Tools

CFPB announces new Project Catalyst project

The CFPB has announced a new project as part of its Project Catalyst initiative, which the CFPB describes as ”designed to encourage consumer-friendly developments in markets for consumer financial products and services.” The...more

9/30/2014 - CFPB Credit Cards Credit Counseling Debt Project Catalyst

Senate passes bill exempting condo unit sales from ILSFDA registration

In May 2013, we reported that the CFPB’s amicus program scored a victory when the U.S. Court of Appeals for the Second Circuit ruled that the sale of a single-floor condominium unit in a multistory building was subject to the...more

9/26/2014 - CFPB Condominiums ILSFDA New Legislation Real Estate Transfers

GAO report finds CFPB needs to improve privacy and security procedures for data collections

A new report from the Government Accountability Office on the CFPB’s data collection efforts finds that the CFPB needs to do more to reduce the risk of improper collection, use or release of such data. The CFPB’s data...more

9/25/2014 - CFPB Data Collection Data Protection GAO

News groups oppose opt in for CFPB’s proposed disclosure of complaint narratives

While industry continues to voice its opposition to the CFPB’s proposal to publicly disclose consumer complaint narratives, some news groups think the CFPB’s proposal doesn’t go far enough. ...more

9/25/2014 - CFPB Complaint Procedures Disclosure Requirements

CFPB and FTC file lawsuits against online payday lenders

Earlier this month, the CFPB and FTC filed lawsuits against different groups of interrelated companies and their individual principals for engaging in allegedly unlawful online payday lending schemes....more

9/19/2014 - CFPB EFTA Enforcement Actions FTC Payday Loans Popular TILA

Florida and Connecticut AGs file lawsuit asserting Dodd-Frank enforcement authority

On July 29, 2014, another Section 1042 lawsuit was filed jointly by the Attorneys General of Florida and Connecticut in a Florida federal court. The lawsuit alleges that four individuals and their four businesses formulated...more

9/18/2014 - Attorney Generals Dodd-Frank Enforcement Mortgage Servicing Rules Mortgages UDAAP

CFPB to hold Oct. 8 forum on checking account screening policies and practices

The CFPB has announced that it will hold a forum on checking account screening policies and practices in Washington, D.C. on October 8, 2014. ...more

9/18/2014 - Banks CFPB Checking Accounts Compliance

Rep. Maloney urges CFPB to limit overdraft fees and expand opt-in rules

Democratic Congresswoman Carolyn Maloney of New York sent a letter to Director Cordray yesterday urging the CFPB to limit overdraft fees and expand opt-in requirements as part of a proposed overdraft rule. In calling...more

9/12/2014 - ACH Payments Banking Sector Banks CFPB Credit Cards Debit Cards Legislative Agendas Opt-In Overdraft Fees

Update on Illinois AG lawsuit using Dodd-Frank authority

As we previously reported, among the lawsuits that have been brought by a state attorney general and a state regulator using their Dodd-Frank enforcement authority is a lawsuit initially filed by the Illinois AG in state...more

9/12/2014 - Colleges Dodd-Frank For Profit Colleges UDAAP Universities

House members propose bill to nullify CFPB indirect auto finance guidance

A bipartisan group of fourteen House members have introduced a bill (H.R. 5403) that would nullify the CFPB’s indirect auto finance guidance issued in March 2013 and require the CFPB to provide for a notice and comment period...more

9/12/2014 - Automotive Industry Automotive Loans CFPB DOJ Federal Reserve FTC Legislative Agendas Minority-Owned Businesses Proposed Legislation Public Comment Small Business Women-Owned Businesses

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