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Regulation Z Ability-to-Repay Banking Sector

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments

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The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more

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CFPB Spring 2017 Supervisory Highlights focuses on mortgage origination/servicing, student loan servicing deficiencies, service...

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The CFPB’s newly-released Spring 2017 edition of Supervisory Highlights covers supervisory activities generally completed between September and December 2016. The report indicates that supervisory resolutions resulted in...more

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ABA highlights error in cost of credit calculation method used in CFPB’s proposed payday loan rule

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At the meeting earlier this month of the American Bar Association’s Consumer Financial Services Committee in Carlsbad, CA, attention was given to an issue highlighted by the American Bankers Association in the comment letter...more

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CFPB issues Fall 2016 Supervisory Highlights

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In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more

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CFPB issues final rule expanding definition of “small creditor” and “rural areas” under TILA

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The CFPB has issued a final rule that revises the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA). The final rule is effective January 1, 2016. We previously reported on...more

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