Disclosure Requirements Consumer Financial Protection Bureau

News & Analysis as of

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

CFPB Issues New Mortgage Disclosure Rule

On October 15, 2015, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). At nearly 800 pages, the new HMDA rule changes (i) the...more

HOLY HMDA! CFPB Finalizes Changes to Home Mortgage Disclosure Rule

On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to...more

Director Cordray sends warning to vendors on TRID rule compliance

In remarks yesterday at the Mortgage Bankers Association’s annual convention, CFPB Director Richard Cordray stated that the CFPB may need to look more closely at vendors of software and other tools used by lenders to comply...more

A Response to the CFPB’S Recent Compliance Bulletin on MSAs

On October 8, 2015, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a Compliance Bulletin on RESPA Compliance and Marketing Services Agreements (“MSAs”)(“Compliance Bulletin”).  The Compliance Bulletin’s...more

Regulators Demand “Good Faith Efforts” for TRID Implementation

Why it matters - Federal regulators said they don’t expect perfection from banks trying to comply with the new mortgage disclosure requirements but will not turn a blind eye with regard to enforcement. In letters to...more

CFPB issues final HMDA rule

The CFPB has issued a final rule amending Regulation C, its Home Mortgage Disclosure Act regulation. The changes, which, in part, implement the Dodd-Frank Act’s amendments to HMDA, expand the scope of data required to be...more

Special Alert: CFPB Adopts Significant Expansion of HMDA Reporting Requirements

On October 15, the Consumer Financial Protection Bureau (the CFPB or Bureau) issued a final rule that will expand the scope of the Home Mortgage Disclosure Act (HMDA) data reporting requirements while seeking to streamline...more

CFPB Finalizes New HMDA Reporting Requirements

The Consumer Financial Protection Bureau (CFPB) finalized a rule yesterday aimed at providing the public and regulators with meaningful information concerning the lending practices of financial institutions....more

Mortgage Applications Decrease in Week Following TRID Implementation

New data from the Mortgage Bankers Association (MBA) shows that total mortgage applications decreased 27.6 percent from the previous week as a result of CFPB’s TILA-RESPA integrated disclosures (TRID) rule, which became...more

Financial Services Weekly News - October 2015 #2

Regulatory Developments: FINRA Proposes Rules for Funding Portals - On Oct. 9 FINRA filed with the SEC a proposed rule change to adopt Funding Portal Rules 100 (general standards), 110 (funding portal application),...more

New Landmark Consumer Disclosure Rules Trigger Privacy Concerns

The Consumer Financial Protection Bureau’s new “Know Before You Owe” mortgage disclosure rule is designed to prevent surprises at the closing table, but with increased transparency come concerns over borrower and seller...more

CFPB Issues TRID FAQs to Help Borrowers Understand the New Mortgage Process

On October 5, the CFPB posted on its blog six FAQs to assist borrowers in understanding the TRID rule and how the new process attempts to make the mortgage process easier. The post comes in light of the TRID rule becoming...more

Members of Congress Recommend Changes to the CFPB’s Proposed Prepaid Account Rule

The comment period to the CFPB’s Notice of Proposed Rulemaking for Prepaid Accounts (the “Proposed Rule”) closed in March, but 43 Members of Congress (42 Republicans and 1 Democrat) recently sent a letter to Director Cordray...more

EXPECT FOCUS: Onboard Technology, NAIC Cybersecurity, DOL, ACA Litigation, SEC Regulation (Vol. III, Summer 2015)

In This Issue: IN THE SPOTLIGHT - - Your Data Breach Collided With My Personal Injury Coverage LIFE INSURANCE - - Phantom Injury Dooms “Shadow Insurance” Case - Latest NAIC Cybersecurity News - A...more

TRID: New Requirements for Real Estate Closing Disclosures Are Here, Will There be A Grace Period?

It’s finally here. Over the weekend, the Consumer Financial Protection Bureau’s (CFPB) long awaited and oft delayed integration of the disclosures required by the Federal Truth in Lending Act (TILA) and Real Estate...more

CFPB Takes Action Against Second Indirect Auto Finance Company in Three Days

On October 1, 2015, the Consumer Financial Protection Bureau (CFPB) announced its second enforcement action in three days against an indirect auto finance company. In its latest action, the CFPB took aim at indirect auto...more

Countdown to TRID Implementation: Blog: Consumer Financial Protection Bureau

The effective date for implementation of the “TILA-RESPA Integrated Disclosure” rule, or “TRID” for short, is just around the corner – October 3rd. Originally the effective date was August 1st but that date was extended by...more

CFPB Releases New Online Tools for Consumers Ahead of the Know Before You Owe Initiative

In November 2013, as mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Consumer Financial Protection Bureau (“CFPB”) combined various federal mortgage disclosures that lenders are required to...more

CFPB seeking approval for national web survey on overdraft disclosures

The CFPB has published a notice indicating that it is seeking approval from the Office of Management and Budget to conduct “a national web survey of 8,000 individuals as part of its study of ATM/debit card overdraft...more

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