News & Analysis as of

Consumer Financial Protection Bureau Disclosure Requirements

The Consumer Financial Protection Bureau is a United States federal agency established in 2010 as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Agency is responsible for educating... more +
The Consumer Financial Protection Bureau is a United States federal agency established in 2010 as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act. The Agency is responsible for educating consumers about financial products and services, enforcing federal consumer financial laws and studying trends in consumer financial markets.     less -

CFPB provides additional HMDA reporting guidance

by Ballard Spahr LLP on

The CFPB issued HMDA Loan Scenarios on July 19, 2017 to provide additional guidance to the industry on reporting transactions under the revised HMDA rule, which has a January 1, 2018 effective date for most provisions....more

CFPB Finalizes TRID Rule Clarifications

by Alston & Bird on

Our Financial Services & Products Group gets to know the Consumer Financial Protection Bureau’s long-awaited final TILA and RESPA Integrated Disclosure (TRID) Rule. - The black hole - Highlighted variations - Possible...more

CFPB Proposes Changes to Home Mortgage Disclosure Act (HMDA) Reporting Threshold for Community Banks and Credit Unions

On July 14, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule on HMDA reporting requirements for banks and credit unions that issue home-equity lines of credit (HELOCs). Under rules scheduled to...more

The CFPB Finalizes Some, But Not All, Amendments to TRID

by Balch & Bingham LLP on

The Consumer Financial Protection Bureau (CFPB) recently finalized various updates to its mortgage disclosure rule, often referred to as “Know Before You Owe” or the TILA-RESPA Integrated Disclosures (TRID). The updates were...more

CFPB Finalizes Amendments to TRID Rule

The Consumer Financial Protection Bureau (CFPB) released final amendments to its “Know Before You Owe” mortgage disclosure rule, which is also known as the TILA-RESPA Integrated Disclosure rule (TRID), on July 7, 2017. As...more

CFPB Finalizes Amendments to the TILA-RESPA Integrated Disclosure (TRID) Rule

On July 7, the Consumer Financial Protection Bureau (Bureau) finalized amendments to federal mortgage disclosure requirements under the Real Estate Settlement Procedures Act (RESPA) and the Truth in Lending Act (TILA) that...more

CFPB Finalizes TRID Rule Amendments, Punts on Black Hole Issue

by Ballard Spahr LLP on

The CFPB finalized the long-awaited initial round of amendments to the TILA/RESPA Integrated Disclosure (TRID) rule, also known as the Know Before Your Owe rule. However, instead of addressing the so-called “black hole”...more

CFPB issues executive summary of TRID Rule amendments

by Ballard Spahr LLP on

The CFPB recently issued final amendments to the TILA/RESPA Integrated Disclosure (TRID) rule and a proposal to further amend the TRID rule.  The CFPB has also issued an Executive Summary of the amendments....more

NJ Assembly contemplates harsh restrictions on prepaid accounts

by Ballard Spahr LLP on

The New Jersey Legislature is considering a law to restrict prepaid-account fees. Assembly Bill 4965 ( the NJ Bill) seeks to impose fee constraints, disclosure mandates, and limits on consumer liability for unauthorized...more

CFPB proposes further changes to the Prepaid Account Rule in response to industry feedback

by Ballard Spahr LLP on

As we previewed earlier this year, the CFPB, on June 15, proposed substantive changes to the Prepaid Final Rule (the “Rule”). The proposed changes are generally positive for prepaid providers and incorporate feedback and...more

Financial Services Report - Summer 2017

by Morrison & Foerster LLP on

EDITOR’S NOTE - Summer blockbuster season is officially upon us. Have you seen Wonder Woman yet? What about Guardians of the Galaxy Part 2? It’s déjà vu all over again with Baywatch, Pirates of the Caribbean, Alien,...more

CFPB Proposes Changes to Prepaid Accounts Rule

by Morrison & Foerster LLP on

On June 15, 2017, the Consumer Financial Protection Bureau (“CFPB”) released proposed revisions to its final Prepaid Accounts Rule (“Final Rule”). The Final Rule was published in November 2016 and was subsequently amended to...more

“Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs” – House Passes Financial Reform Bill

by Snell & Wilmer on

On June 8, the House of Representatives passed the Financial CHOICE Act of 2017 in a bid to reform the financial regulatory system created by the Dodd-Frank Wall Street Reform and Consumer Protection Act. The bill, which...more

Propoposed Bill Would Significantly Expand MLA Disclosure Requirements

by Ballard Spahr LLP on

We recently reported on a bill introduced in the House of Representatives by Congressman Dan Kildee (D-Michigan) that would amend the Military Lending Act (“MLA”) to require that creditors provide additional disclosures to...more

CFPB to seek OMB approval of survey on debt collection disclosures

by Ballard Spahr LLP on

In a notice published earlier this week in the Federal Register, the CFPB announced that it plans to seek OMB approval to conduct an online survey of approximately 8,000 individuals as part of its research on debt collection...more

CFPB Delays Effective Date of Prepaid Accounts Rule – How Can You Prepare?

by Baker Donelson on

The CFPB has provided additional time to prepare for its long-anticipated prepaid accounts rule, moving the rule's effective date from October 1, 2017 to April 1, 2018. Per the CFPB, the delay will allow industry participants...more

CFPB prepaid card rule survives Senate CRA challenge

by Ballard Spahr LLP on

The CFPB’s final prepaid card rule has survived Republican efforts to nullify the rule under the Congressional Review Act (CRA). The CRA establishes a special set of procedures through which Congress can nullify final...more

ABA comments on CFPB’s RFI on consumer access to financial information

by Ballard Spahr LLP on

The American Bankers Association has submitted a comment letter in response to the CFPB’s request for information regarding consumer access to financial information. The ABA observes that while larger institutions have...more

New CFPB webinar available on 2015 HMDA final rule

by Ballard Spahr LLP on

On October 15, 2015, the CFPB released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring certain data on mortgage applications and loans to be collected beginning in 2017...more

CFPB and Virginia AG settle claims against pawnbroker for alleged TILA/CFPA/VA law violations

by Ballard Spahr LLP on

The CFPB and the Virginia Attorney General announced that they had entered into a proposed consent order with  Woodbridge Coins and Jewelry Exchange, Inc., a Virginia-based pawnbroker, to settle a lawsuit filed in a Virginia...more

CFPB continues work on student loan payback playbook disclosures

by Ballard Spahr LLP on

The CFPB recently revised the prototype student loan Payback Playbook disclosures it has been developing with the Departments of Education and Treasury. These revisions were based on feedback from nearly 3,500 individual...more

The looming student debt crackdown: compliance and enforcement lessons from the foreclosure crisis

Given the parallels between the current student loan debt crisis (including the CFPB, Illinois and Washington’s recent lawsuits against Navient) and the foreclosure crisis of 2010-14, now is a good time to reflect on the...more

CFPB Consent Orders with Consumer Reporting Agencies Focus on Marketing Practices not Credit Reporting

Marketing practices remain at the forefront of CFPB activity as evidenced by two recent consent orders entered into with TransUnion and Equifax. The consent orders combine to require the CRAs to pay more than $17.6 million...more

2016 Year In Review: Securities Litigation And Regulation

2016 was an active year in securities litigation. In the first half of 2016 alone, plaintiffs filed 119 new federal class action securities cases. It was also a busy year for SEC enforcement proceedings, with a record 868...more

Proposed CFPB Regulations Seek to Expand Agency’s Disclosure Opportunities

by Polsinelli on

The federal Consumer Financial Protection Board (CFPB) has proposed new regulations and changes to its existing regulations that expand the agency's ability to disclose information to others, potentially compromising the...more

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