Episode 25: 10 Factors That May Hinder a Contractor’s Ability to Repay Its Bank Loans and Threaten Its Existence
Critical Mortgage Regulatory Updates by the Consumer Financial Protection Bureau for 2013 and 2014
1. FDIC Proposes Changes to Deposit Insurance Assessment Rule for CBLR Banks The FDIC has published a proposal that describes how the agency would apply the Community Bank Leverage Ratio (“CBLR”) framework previously...more
Kilpatrick Townsend’s Sam Arora recently presented at the Texas Organization of Financial Service Centers’ (TOFSC) Annual Conference on “CFPB: Updates on Litigation re: Small Dollar Loans”. The TOFSC was attended by many of...more
On Tuesday, the small-dollar lending industry received a favorable ruling in Community Financial Services Association of America v. CFPB. A Texas federal court reversed course by staying the August 19, 2019, compliance date...more
A group of Democratic senators (joined by two independent Senators) has sent a letter to Leandra English and Mick Mulvaney urging them to abandon any efforts by the CFPB to reconsider its final payday/auto title/high-rate...more
The American Banker has reported that last week, Senator Lindsey Graham introduced a joint resolution under the Congressional Review Act (CRA) to override the CFPB’s final payday/auto title/high-rate installment loan rule...more
On January 16, the CFPB announced plans to “reconsider” its newly minted regulation for Payday, Vehicle Title, and Certain High-Cost Installment Loans (the Payday Rule)....more
A bipartisan group of lawmakers has introduced a joint resolution under the Congressional Review Act to override the CFPB’s final payday/auto title/high-rate installment loan rule. House members sponsoring the bill consist...more
The CFPB’s final payday loan rule was published in today’s Federal Register. Lenders covered by the rule include nonbank entities as well as banks and credit unions. In addition to payday loans, the rule covers auto title...more
Hours after the CFPB released its final payday/auto title/high-rate installment loan rule on October 5, 2017, the OCC rescinded its guidance on deposit advance products. ...more
On October 5, the CFPB issued it long-anticipated Payday, Vehicle Title, and Certain High-Cost Lending Rule covering certain short-term loans. The final regulation, published more than 15 months after it was proposed in June...more
The CFPB issued its final payday loan rule last week in a release running 1,690 pages. Lenders covered by the rule include nonbank entities as well as banks and credit unions. In addition to payday loans, the rule covers...more
The Consumer Financial Protection Bureau (CFPB) issued its final payday loan rule last week in a release running 1,690 pages. Lenders covered by the rule include nonbank entities as well as banks and credit unions....more
It will take a while to digest the CFPB’s 1,700-page release on payday, title and high-rate installment lending but, naturally, I have a number of preliminary observations...more
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more
On August 21, 2017, the Office of the Comptroller of the Currency (OCC) published Bulletin 2017-28 regarding higher-loan-to-value (LTV) lending programs (the “Bulletin”). Recognizing the need for further revitalization...more
The CFPB’s newly-released Spring 2017 edition of Supervisory Highlights covers supervisory activities generally completed between September and December 2016. The report indicates that supervisory resolutions resulted in...more
Dovetailing with President Trump’s recent Executive Order requiring a reduction in regulatory burden, on March 21, 2017, a CFPB official remarked at the American Bankers Association Government Relations Summit that the CFPB...more
At the meeting earlier this month of the American Bar Association’s Consumer Financial Services Committee in Carlsbad, CA, attention was given to an issue highlighted by the American Bankers Association in the comment letter...more
In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more
The Small Business Administration’s Office of Advocacy has submitted a comment letter on the CFPB’s proposed payday loan rule that raises concerns about the proposal’s economic impact on small businesses and encourages the...more
The comment period for the CFPB’s proposed rule on Payday, Title and High-Cost Installment Loans ended Friday, October 7, 2016. The CFPB has its work cut out for it in analyzing and responding to the comments it has...more
The Small Business Administration’s Office of Advocacy will host a roundtable in London, Kentucky on September 14, 2016 on the CFPB’s proposed payday loan rule. As the Office of Advocacy is an independent office within the...more
The CFPB is publishing a notice in tomorrow’s Federal Register to correct the comment deadline for its payday loan Request for Information (RFI). The corrected deadline will be November 7, 2016. The RFI seeks feedback...more
The CFPB’s proposed payday loan rule and related Request for Information (RFI) were published in this past Friday’s Federal Register. The RFI seeks feedback regarding consumer protection concerns pertaining to (1) loan...more
A group of 27 Democratic Senators joined by Independent Senator Bernie Sanders have sent a letter to Director Cordray urging the CFPB to “strengthen” its proposed payday loan rule. The Senators take aim at the proposal’s...more