News & Analysis as of

National Credit Union Administration Ability-to-Repay Consumer Financial Protection Bureau (CFPB)

Ballard Spahr LLP

Federal banking agencies and CFPB issue interagency statement on use of alternative data in credit underwriting

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The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more

Morrison & Foerster LLP

A Closer Look at the CFPB’s Proposed Short-Term Lending Rule

As we previously reported in our June 3, 2016 client alert, the Consumer Financial Protection Bureau (“CFPB”) has issued a Notice of Proposed Rulemaking for short-term loans (“Proposed Rule”). In this follow-up alert, we take...more

Manatt, Phelps & Phillips, LLP

CFPB Releases Proposed Regulation of Payday Loans

In a long anticipated move, the Consumer Financial Protection Bureau (CFPB) proposed a rule to regulate so-called "debt traps" by requiring lenders to take additional steps to ensure consumers have the ability to repay...more

Ballard Spahr LLP

CFPB issues proposed payday/auto title/high-rate installment loan rule

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As expected, the CFPB issued its proposed payday loan rule, in a release running 1,334 pages. The CFPB also issued a fact sheet summarizing the proposal. Once we complete our initial review of the proposal, we will issue a...more

Ballard Spahr LLP

Prudential Regulators Clarify Supervisory Approach Relative to CFPB Mortgage Regulation

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The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Prudential Regulators”) have...more

Goodwin

Federal Regulators Issue Statement on Fair Lending Compliance and the Ability-to-Repay and Qualified Mortgage Rules

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In response to inquiries from creditors about liability under the Equal Credit Opportunity Act’s disparate impact doctrine on originating qualified mortgages under the CFPB’s ability-to-repay provisions, the CFPB, OCC, FRB,...more

Morrison & Foerster LLP

Interagency Fair Lending Guidance: A First Step, but in the Right Direction?

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Five federal regulators, with HUD noticeably absent, issued the first interagency guidance on the much-debated intersection of fair lending enforcement and the Ability-to-Repay and Qualified Mortgage Standards Rule taking...more

Ballard Spahr LLP

CFPB joins interagency statement on qualified mortgage fair lending risks

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The CFPB was one of five federal regulators issuing an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the CFPB’s ability-to-repay/qualified...more

Ballard Spahr LLP

Federal Regulators Issue Statement on Qualified Mortgage Fair Lending Risks

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Federal regulators have issued an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the Consumer Financial Protection Bureau’s...more

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