Topics In This Issue
• Federal Issues
• State Issues
• Firm News
• Consumer Finance
• Privacy/Data Security
• Criminal Enforcement Actions
Excerpt from "Federal Issues"
CFPB Transfer Date Set for July 2011; Elizabeth Warren to Lead CFPB Formation Effort. On September 20, 2010, the Treasury Department announced that July 21, 2011 will be the "designated transfer date" on which certain authorities will be transferred to the Bureau of Consumer Financial Protection (the "CFPB") pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act").
On that date, among other things, the CFPB will:
• Receive its full authority to prescribe rules or issue orders pursuant to any federal consumer financial law (as defined in the Dodd-Frank Act);
• Officially receive staff transfers from the other agencies; and
• Become responsible for the supervision of depository institutions with assets of greater than $10 billion.
The Federal Register notice also states that, prior to July 21, 2011, the CFPB will begin conducting research on consumer financial products and services, develop its nationwide consumer complaint response center, and begin to plan implementation of its risk-based supervision of nondepository covered persons. In addition, the CFPB is planning a roundtable discussion to begin the process of merging Truth in Lending and RESPA disclosures. The establishment of the "designated transfer date" also locks in the timeline for implementing the Dodd-Frank Act’s mortgage reforms contained in Title XIV. For Title XIV provisions where regulations are required to implement the provision, the Board or CFPB must issue its final rules by January 21, 2013. The rules must take effect within one-year of issuance, meaning that compliance with all rules would be required at the latest by January 21, 2014. If the agencies fail to issue implementing regulations, the statutory language will take effect on January 21, 2013.
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