Disclosure Requirements Consumer Financial Protection Bureau

News & Analysis as of

CFPB Announces Plan to Promulgate Key Mortgage Disclosure Rule

Consumer Financial Protection Bureau (CFPB) Director Richard Cordray recently informed several banking and other industry groups that the Bureau plans to introduce a proposed rule to address concerns related to CFPB mortgage...more

CFPB Publishes New Annotated Loan Disclosures

In emails sent to CFPB email subscription holders, the CFPB announced the publication of new annotated versions of the Loan Estimate and Closing Disclosure that include citations to sections in Chapter 2 of the Truth in...more

CFPB Amends Regulations J and L of Interstate Land Sales Full Disclosure Act to Allow Electronic Filings

On May 2, the CFPB announced that it is amending implementing Regulations J and L of the Interstate Land Sales Full Disclosure Act (ILSA) to permit electronic filings. Pursuant to ILSA, certain land developers must register...more

CFPB Staff Presents Second TRID Rule Webinar for 2016

The CFPB staff presented an informational webinar on Tuesday, April 12, 2016, to address several issues with the TILA/RESPA Integrated Disclosure (TRID) rule. The webinar, titled Know Before You Owe Mortgage Disclosure Rule:...more

The TRID Rule: Impact and Consequences on the Residential Mortgage Lending Market

Introduction and Background - Residential mortgage lenders have long been required to disclose to their borrowers (i) the cost of credit to the consumer and (ii) the cost to the consumer of closing the loan transaction....more

CFPB finalizes no-action policy for innovative financial products

The CFPB has issued a final policy statement on issuing “no-action” letters (NAL) for innovative financial products or services. The CFPB’s statement that the final policy was released on its website on February 18, 2016...more

CFPB Agrees to Give Originators a Grace Period for Compliance with New TRID Regulations

On the eve of the New Year, the Consumer Financial Protection Bureau (CFPB) took steps to calm industry concerns about the effect of the new TILA RESPA Integrated Disclosure (TRID) rules enacted by the CFPB. Effective October...more

CFPB Releases TRID Resource for Construction Loans

Recently, the CFPB released a fact sheet that provides a basic outline for applying Know Before You Owe mortgage disclosures to constructions loans. Specifically, the fact sheet notes that (i) most construction loans are...more

Increased Government Scrutiny of Ads on Social Media Expected in 2016

Recent statements and actions by the Federal Trade Commission, the Food and Drug Administration and the Consumer Financial Protection Bureau forewarn of additional regulatory enforcement of advertisements on social...more

CFPB Releases Guidance on Construction Loan Disclosures

On January 12, the CFPB released a Construction Loans Fact Sheet reviewing the basics of construction loan disclosures under the TILA/RESPA Integrated Disclosure (“TRID”) Rule. This resource briefly summarizes the TRID...more

CFPB construction loan “fact sheet” falls far short of necessary guidance

The CFPB has issued what it calls a “fact sheet” regarding the disclosure of construction-to-permanent loans under the TILA/RESPA Integrated Disclosure (TRID) rule, which the CFPB refers to as the Know Before You Owe rule....more

Seller Beware: Lessons Learned from 2015 Deceptive Advertising Enforcement in the Consumer Finance Space

Federal regulators took a close look at advertisements for consumer financial products and services in 2015, bringing over 25 enforcement actions totaling over $975 million in penalties and consumer redress. In the majority...more

FAST Act Drives Long-Awaited Gramm-Leach-Bliley Amendment

In late 2015, Congress passed the Fixing America’s Surface Transportation Act - a vehicle for an amendment to the Gramm-Leach-Bliley Act (GLBA) meant to eliminate the need for certain companies to provide annual privacy...more

CFPB Issues Request for Information Regarding HMDA Disclosure Guidelines

On January 7, the CFPB announced that it will request public feedback on the resubmission of mortgage lending data reported under HMDA. Upon publication in the Federal Register, the Request for Information Regarding Home...more

TRID Liability Will Be A Dominant Issue In 2016

Oct. 3, 2015, was a watershed moment for the mortgage origination industry and the Consumer Financial Protection Bureau. On that date, the CFPB’s long-awaited Know Before You Owe: TILA-RESPA Integrated Disclosure (TRID) rule...more

Special Alert: CFPB Director Opines on TRID Liability

On December 29, 2015, CFPB Director Richard Cordray issued a letter in response to concerns raised by the Mortgage Bankers Association regarding violations of the CFPB’s new TILA-RESPA Integrated Disclosure (“TRID”) rule,...more

CFPB Issues Major Changes to HMDA Requirements

The Consumer Financial Protection Bureau (“CFPB”) has issued a final rule with major changes to Regulation C, which implements the Home Mortgage Disclosure Act (“HMDA”). Among other things, the new HMDA rule (“HMDA Rule” or...more

CFPB Reports on Credit Card Agreements and Warns Colleges of Potential CARD Act Violations

On December 16, the CFPB issued its annual report to Congress regarding credit card marketing agreements between colleges and issuing credit card organizations. Pursuant the Credit Card Accountability, Responsibility, and...more

CFPB releases report on college credit card agreements, student account toolkit and warning letters

Earlier this week, the CFPB released  its sixth annual report on college credit card agreements, together with a new toolkit for schools to use when considering potential co-sponsorships of financial accounts, such as prepaid...more

U.S. Department of Education Turns Eye to Regulating Financial Services Industry

On October 27, 2015, the United States Department of Education issued 433 pages of new regulations governing student loan programs under the Student Assistance General Provisions regulations promulgated under the Higher...more

Dodd-Frank News: November 2015: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

The Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted as a measure to promote financial stability and protection for consumers through increased regulation of nearly every aspect of the consumer finance...more

TRID's Closing Disclosure

On October 3, 2015, the new TILA-RESPA Integrated Disclosures Rule (TRID) went into effect. The rule sought to streamline and clarify some of the overlapping and confusing language on the two different disclosure forms...more

CFPB Finalizes Rule to Improve Information About Access to Credit in the Mortgage Market

On October 15, 2015, the Consumer Financial Protection Bureau issued a final rule that revised the reporting requirements under the Home Mortgage Disclosure Act. Most of these changes take effect on January 1, 2018....more

Key Takeaways from the Consumer Protection Forum

Holland & Knight and the Word of Mouth Marketing Association (WOMMA) hosted a half-day forum that featured government officials discussing hot-button issues in consumer protection regulation and enforcement. Speakers at the...more

Financial Services Weekly News - October 2015 #3

Regulatory Developments: FINRA Requests Comment on Rules Relating to Financial Exploitation of Vulnerable Adults - On Oct. 15 FINRA published Regulatory Notice 15-37, requesting comment on proposed amendments to...more

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