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 -

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

CFPB’s Prepaid Card Rule: Short Form Disclosure Requirements

by Ballard Spahr LLP on

The CFPB’s Final Rule on prepaid cards includes, in addition to the long form disclosure requirements discussed in our November 21st blog post, highly detailed requirements for providing “preacquisition” disclosures to...more

CFPB’s Final Prepaid Card Rule: Long Form Disclosures

by Ballard Spahr LLP on

The final Prepaid Card Rule requires not only so-called “packaging” or short form disclosures prior to acquisition of the prepaid card account, but also that a long form disclosure be provided to the consumer. Whereas the...more

What To Know About CFPB's New Prepaid Card Rule

by Morrison & Foerster LLP on

The Consumer Financial Protection Bureau issued its final rule to amend provisions of Regulation E and Regulation Z to further regulate prepaid card products, or “prepaid accounts.” As discussed below, the rule generally...more

CFPB Warns Mortgage Lenders and Brokers of Possible HMDA Violations

by BakerHostetler on

On Oct. 27, 2016, the Consumer Financial Protection Bureau (CFPB) warned 44 unnamed mortgage lenders and brokers that they may be in violation of data reporting requirements of the Home Mortgage Disclosure Act...more

CFPB sending HMDA warning letters

by Ballard Spahr LLP on

The CFPB announced that it is issuing warning letters to 44 mortgage lenders and mortgage brokers stating that it “has information that appears to show that your company may not be in compliance with certain provisions of the...more

The ILSA Condo Exemption – Not Out of the Woods Yet

by Carlton Fields on

The Interstate Land Sales Full Disclosure Act (ILSA) is a federal statute that aims to prevent land sales fraud and uninformed purchases of unimproved real property by requiring registration of subdivisions with the Consumer...more

The Prepaid Rule is Finally Here

Last week, the CFPB issued its long-awaited final rule amending Regulation E (Electronic Funds Transfer Act) and Regulation Z (Truth in Lending Act) to create regulations for prepaid financial products (Prepaid Rule). The...more

Orrick's Financial Industry Week In Review

Financial Industry Developments - The CFPB Publishes Final Rule for Prepaid Accounts - On October 5, 2016, the Consumer Financial Protection Bureau (the "CFPB") finalized comprehensive consumer protections for...more

CFPB Finalizes Prepaid Card Rule …and the Clock is Ticking

by White & Case LLP on

On October 5, 2016, the Consumer Financial Protection Bureau (the “CFPB” or the “Bureau”) released its long-awaited final rule on prepaid cards (the “Final Rule”). The 1689-page Final Rule will fundamentally change how...more

CFPB finalizes sweeping expansion of prepaid account regulations

by Ballard Spahr LLP on

The CFPB has issued its long-anticipated final rule for general purpose prepaid accounts.  As expected, the new regulations expand the products covered by Regulation E, introduce significant new disclosure requirements,...more

CFPB enters into consent order with auto title lender

by Ballard Spahr LLP on

The CFPB announced that it has entered into a consent order with TMX Finance, LLC to settle allegations that the company did not provide sufficient information to consumers about the terms of auto title loans, pawns or...more

CFPB participates in FTC workshop on disclosure

by Ballard Spahr LLP on

The FTC recently held a workshop, “Putting Disclosures to the Test,” to explore the question of what should be done to make disclosures effective.  The workshop included reports on numerous studies related to consumer...more

To (Dis)Close for Comfort–FTC Workshop Seeks Effective Consumer Disclosures

by Ballard Spahr LLP on

A goal of providing effective disclosures to consumers is to allow consumers to make informed decisions. But what must be done to make disclosures effective? This was the question the Federal Trade Commission (FTC) explored...more

CFPB Proposal to Relax Standards for the Discretionary Disclosure of Confidential Supervisory Information

by Poyner Spruill LLP on

In a proposed rule set forth in the August 24, 2016 Federal Register, the Consumer Financial Protection Bureau (Bureau) suggests “amendments relating to the disclosure of records and information.” While the proposal touches...more

CFPB Proposes Changes to Mortgage Industry

by Davis Wright Tremaine LLP on

The Consumer Financial Protection Bureau recently issued a proposed rule regarding integrated disclosure for mortgage transactions and, more recently, published a policy paper regarding loss mitigation programs in housing...more

CFPB Presents Significant New Regulatory Requirements for Third-Party Debt Collectors

by Stinson Leonard Street on

On July 28, 2016, the Consumer Financial Protection Bureau (CFPB) released an outline of proposals and alternatives under consideration for regulating debt collection practices. The outline’s release triggers the formation of...more

CFPB Official Offers Update and Guidance on Regulations

by Davis Wright Tremaine LLP on

This morning we attended the meeting of the Financial Services Roundtable’s Consumer Working Group, which featured a presentation by David Silberman, Acting Deputy Director of the Consumer Financial Protection...more

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