Leonard N. Chanin

Leonard N. Chanin

Morrison & Foerster LLP

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HOLY HMDA! CFPB Finalizes Changes to Home Mortgage Disclosure Rule

On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to...more

10/21/2015 - CFPB Covered Financial Institutions Covered Transactions Data Collection Depository Institutions Disclosure Requirements Final Rules HMDA Mortgage Lenders Mortgage Servicers Mortgages Public Disclosure Regulation C Reporting Requirements

Department of Defense Adopts Significant Changes to Its Military Lending Act Regulations

On July 22, 2015, the Department of Defense (DOD) published sweeping changes to its rules that implement the Military Lending Act (MLA). The amended rules significantly expand the scope of the MLA provisions by covering both...more

8/3/2015 - Active Duty Amended Regulation Borrowers CFPB Consumer Reporting Agencies Credit Cards Creditors Disclosure Requirements DOD Finance Charges Lenders Loans Military Lending Act Payday Loans Regulation Z

CFPB Announces Field Hearing on Arbitration

On February 23, 2015, the Consumer Financial Protection Bureau (CFPB) announced that it will hold a field hearing in Newark, New Jersey, on March 10, 2015, to discuss the topic of arbitration. We anticipate that the CFPB will...more

2/25/2015 - Arbitration CFPB Dodd-Frank

The CFPB 2015 Forecast: Continued Cloudiness, Thunderstorms Likely

This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more

1/26/2015 - Automotive Loans Banking Sector CFPB Consumer Lenders Debt Collection ECOA Financial Institutions HMDA Integrated Disclosures Mortgage Lenders Mortgages Prepaid Payment Products Proposed Regulation Regulation C RESPA Supervision Truth in Lending Act (TILA) UDAAP

CFPB Weighs in on Department of Defense Military Lending Act Proposed Rule

On December 29, 2014, the Consumer Financial Protection Bureau (CFPB) released a report, entitled “The Extension of High-Cost Credit to Servicemembers and Their Families” (“Report”). According to the CFPB, the Report provides...more

1/2/2015 - CFPB Consumer Lenders DOD Lenders Military Lending Act Military Service Members

DOD Proposes Significant Expansion of Military Lending Act Protections

On September 29, 2014, the Department of Defense (DOD) published a proposed rule in the Federal Register to amend its regulation implementing the Military Lending Act (MLA), 32 C.F.R. Part 232, to significantly expand the...more

10/6/2014 - Banking Sector Banks CFPB Consumer Lenders Credit Cards Creditors DOD Military Lending Act Military Service Members Veterans

CFPB Issues Warning to Credit Card Issuers: Promotional APR Offers May Be Deceptive and/or Abusive

On September 3, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a bulletin to warn credit card issuers about marketing practices related to credit card promotional APR offers (“Bulletin”). The Bulletin warns...more

9/5/2014 - Banking Sector Banks CFPB Credit Cards Dodd-Frank Interest Rates Unfair or Deceptive Trade Practices

CFPB Proposal Would Make 'HMDites' Of Us All

On July 24, the Consumer Financial Protection Bureau published long-awaited proposed revisions to its Home Mortgage Disclosure Act rules. The 573-page proposed rule would make sweeping changes to Regulation C, which...more

8/18/2014 - CFPB Compliance HMDA Mortgages Regulation C

Just When You Thought It Was Safe to Take a Summer Vacation: CFPB Proposes Extensive New HMDA Rules

Last Thursday, the Consumer Financial Protection Bureau (CFPB) published its long-awaited new proposed revisions to its Home Mortgage Disclosure Act (HMDA) rules. The 573-page proposed rules would make sweeping changes to...more

7/28/2014 - CFPB Compliance Fair Lending HMDA Mortgages Reporting Requirements

CFPB Announces Potential Model Packaging Disclosures for GPR Prepaid Cards

On March 18, 2014, the Consumer Financial Protection Bureau (CFPB) continued its long march toward regulating general-purpose reloadable (GPR) prepaid cards by releasing test model disclosures for prepaid card packaging that...more

3/24/2014 - CFPB OMB Prepaid Payment Products

CFPB Increases Penalty Fee Safe Harbor Amounts for Card Issuers

In yesterday’s Federal Register, the Consumer Financial Protection Bureau (“CFPB”) published an amendment to the safe harbor thresholds for credit card penalty fees found in Section 1026.52(b)(1)(ii) of Regulation Z to...more

12/18/2013 - CFPB Consumer Price Index Regulation Z Safe Harbors

FDCPA & More: CFPB Considers “Modern” Methods of Consumer Communications

On November 12, 2013, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published an advance notice of proposed rulemaking (“ANPR”) in the Federal Register seeking information from the public about the operations,...more

11/21/2013 - CFPB Creditors Debt Collection FCRA FDCPA Social Media

How to Be a Good Corporate Citizen CFPB Style

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2013-06 identifying “responsible business conduct” that may impact the exercise of its “enforcement discretion.” The Bulletin specifies the...more

7/5/2013 - CFPB Compliance Enforcement Actions Remediation Responsible Business Conduct Self-Policing Self-Reporting

CFPB Fair Lending Guidance for Indirect Auto Lenders—It’s Not Just About Cars

Several weeks ago, the Consumer Financial Protection Bureau (“CFPB”) issued a fair lending guidance bulletin (“Bulletin”) directed at financial institutions that make indirect automobile loans. While the Bulletin thus far has...more

6/5/2013 - Automotive Industry CFPB Compliance Dodd-Frank DOJ ECOA Enforcement Fair Lending HMDA Nissan Regulation B Rulemaking Process

CFPB Uses Novel Interpretation, Increases Compliance Burden for Gift Card Issuers Through its First Preemption Determination

On April 19, 2013, the Consumer Financial Protection Bureau (“CFPB”) announced it was making a determination to preempt a provision of Tennessee unclaimed property law that it deemed inconsistent with the federal Electronic...more

4/24/2013 - CFPB Disclosure Requirements EFTA Gift-Cards Preemption Regulation E Unclaimed Property

Financial Services Report - Spring 2013

Editor’s Note - This is a dignified law firm newsletter, not like the “Brand X” versions. You won’t find pandering, attention-grabbing stories about Justin Bieber, Kim Kardashian, Ashton Kutcher, Prince William, or...more

3/13/2013 - Arbitration Barack Obama CFPB China Credit Reports Cybersecurity Data Protection Debt Collection Dodd-Frank Dukes v Wal-Mart Fair Housing Act (FHA) FDCPA FDIA FDIC Federal Reserve Foreclosure FTC Mobile Apps Recess Appointments Richard Cordray Social Media Telemarketing

CFPB Ability to Repay Rules Issued

On January 10, 2013, the Consumer Financial Protection Bureau issued much-anticipated revisions to Regulation Z to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that require lenders to...more

1/29/2013 - Ability-to-Repay CFPB Mortgage Loan Originators Mortgages Qualified Mortgage Rule Regulation Z Safe Harbors

Dodd-Frank Implementation: Navigating the Road Ahead

Table of Contents: Introduction; Financial Stability Reform; Resolution Planning; Agencies and Agency Oversight Reform; Securitization Reform; Derivatives Regulation; Investor Protection Reform; Credit Rating Agency...more

12/29/2012 - Capital Requirements CFPB Corporate Governance Credit Ratings Derivatives Disclosure Requirements Dodd-Frank Financial Stability Acts Foreign Banks Mortgage Loan Originators Mortgages Securitization Servicing Policies Volcker Rule

Financial Services Report -- Winter 2012

In This Issue: Bureau Report; Operations Report; Beltway Report; Arbitration Report; Mortgage Report; Privacy Report; Preemption Report; and Plastics Report. Excerpt from the Bureau Report: World’s Most...more

12/18/2012 - American Express CFPB Chase Bank Cybersecurity Debt Collection Dodd-Frank FDIC FTC Google Mobile Apps MySpace Project Catalyst Stress Tests Truth in Lending Act (TILA)

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