News & Analysis as of

Truth in Lending Act (TILA) Regulation Z Banks

Ballard Spahr LLP

In Rare Move, the CFPB Comes to the Defense of Bank

Ballard Spahr LLP on

In an unusual move, the CFPB is coming to the defense of a bank being accused of failing to provide repayment disclosures to a borrower....more

Sheppard Mullin Richter & Hampton LLP

Takeaways From the FDIC’s Spring 2024 Consumer Compliance Supervisory Highlights

On March 28, the FDIC released the spring edition of its consumer compliance supervisory highlights. The FDIC supervises approximately 3,000 state-chartered banks and thrifts that are not members of the Federal Reserve...more

Goodwin

The CFPB’s “Junk Fees” Initiative: Recent Developments and Trends

Goodwin on

The term “junk fee” is not defined under federal law, but the CFPB has focused on factors such as whether the fee would be unexpected to or take advantage of a reasonable consumer, the amount of the fee compared to the cost...more

Latham & Watkins LLP

CFPB Proposes to Prohibit Non-Sufficient Funds Fees on Declined Transactions

Latham & Watkins LLP on

As person-to-person payments become mainstream, the proposal would proactively outlaw fees that financial institutions could assess on instantaneously declined transactions. On January 24, 2024, the Consumer Financial...more

Hudson Cook, LLP

CFPB Bites of the Month - December 2023 - I'm Dreaming of a Winter Solstice and the CFPB

Hudson Cook, LLP on

In this month's article, we share some of our top "bites" for the prior month covered during the December 2023 webinar....more

Hudson Cook, LLP

CFPB Fines Large National Bank for Withholding Credit Card Rewards, Charging Multiple Non-sufficient Fund Fees, and Opening...

Hudson Cook, LLP on

On July 11, 2023, the CFPB announced two consent orders against a large national bank, settling allegations that the bank illegally charged consumers multiple non-sufficient fund fees for the same transaction, withheld cash...more

Ballard Spahr LLP

CFPB Adjusts HMDA and TILA Asset Exemption Thresholds

Ballard Spahr LLP on

The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more

Bradley Arant Boult Cummings LLP

OCC Releases Final True Lender Rule

On October 27, 2020, the OCC released its final True Lender Rule. As discussed earlier on this blog, the OCC’s rule is designed to clarify the “true lender” doctrine, a legal test utilized by courts and regulators to...more

Goodwin

CFPB Files Suit Against National Bank Concerning Alleged Unauthorized Accounts

Goodwin on

On March 9, 2020, the Consumer Financial Protection Bureau (CFPB) filed a lawsuit against a national bank in the U.S. District Court for the Northern District of Illinois alleging that the bank opened unauthorized accounts...more

Ballard Spahr LLP

CFPB announces annual adjustments to HMDA/TILA asset-size exemption thresholds

Ballard Spahr LLP on

The CFPB has announced annual adjustments to two asset-size exemption thresholds. First, the CFPB has made no change to the asset-size exemption threshold under HMDA/Regulation C which is currently set at $44 million. ...more

Troutman Pepper

Observation 2.0: The Anti-Evasion Provision of the Volcker Rule

Troutman Pepper on

Overview This Client Alert continues Pepper’s observations on the Volcker Rule. Critical attention should be paid to the Volcker Rule’s anti-evasion provision, a powerful tool granted by Congress to the regulatory agencies to...more

Morrison & Foerster LLP

Overview of the CFPB Prepaid Account Proposed Rule

Morrison & Foerster LLP on

On November 13, 2014, the Consumer Financial Protection Bureau (“CFPB”) issued a proposed rule to regulate prepaid accounts (the “Proposed Rule”). The Proposed Rule follows the CFPB’s May 2012 advance notice of proposed...more

Nexsen Pruet, PLLC

Changes to Mortgage Servicing Rules - Blog: Consumer Financial Protection Bureau

Nexsen Pruet, PLLC on

Armed with some background on what the Consumer Financial Protection Bureau (“CFPB”) is and does (from my 11-11-14 blog entry), let’s dive directly into the issue of rules. For starters, let’s look into the CFPB’s new rules...more

Burr & Forman

Dodd-Frank News: May 2014: Dodd-Frank Wall Street Reform and Consumer Protection Act Update

Burr & Forman on

In This Issue: - RECENT CASES ..Preemption ..CFPB Involvement in Litigation ..CFTC Regulation of Retail Commodity Transactions ..Durbin Amendment ..Appraiser Disclosure Requirements Under...more

Ballard Spahr LLP

CFPB adjusts HMDA data collection and TILA mortgage escrow thresholds

Ballard Spahr LLP on

In notices published in yesterday’s Federal Register, the CFPB adjusted the thresholds of the asset-size exemptions for collecting HMDA data and establishing an escrow account for certain mortgage loans under TILA. ...more

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