News & Analysis as of

CFPB Publishes Final Rule Adopting December 2011 Interim Final Rules

On April 28, the CFPB published a final rule to adopt interim final rules issued in December 2011. Pursuant to the Dodd-Frank Act, the CFPB has rulemaking authority for various consumer financial protection laws, as...more

CFPB Director Cordray Responds to Senator Corker Letter

The CFPB responded to a letter from Senator Corker (R. Tenn.) requesting the Bureau to release official guidance on what constitutes a technical error under the TILA/RESPA Integrated Disclosure (TRID) rule and possible...more

Current Developments In Risk Management For Mortgage Brokers

Whether a mortgage broker is acting as the agent of a borrower in negotiating a loan from a wholesale lender, or arranging a loan by bringing together a proposed borrower and lender, or acting as a lender and originating the...more

The Equal Opportunity Enforcer

The CFPB has always said that one of its key missions is to level the playing field for bank and non-bank consumer financial services providers. CFPB Director Richard Cordray, when still only the Assistant Director of...more

CFPB Enforcement Update

This update analyzes the trends and patterns in the Consumer Financial Protection Bureau’s publicly available enforcement actions. Leveraging the analysis in our December 2014 White Paper, CFPB Enforcement by the Numbers...more

Dodd-Frank News: January 2016: 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

Community Banks Face Ever-Increasing Compliance Burden As a Result of Dodd-Frank Rules

According to a “Dodd-Frank Regulations Impacts on Community Banks, Credit Unions and Systematically Important Institutions” report recently released by the Government Accountability Office (GAO), community banks continue to...more

TRID: The Next Consumer Litigation Frontier?

The residential mortgage market underwent a significant regulatory change on October 3, 2015, when the TILA-RESPA Integrated Disclosure (TRID) rule went into effect.  TRID was promulgated by the Consumer Financial Protection...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: 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

The New TILA-RESPA Integrated Disclosure Requirements

Farewell, HUD-1, we hardly knew ye. As of October 3rd, 2015, lenders will provide two integrated forms at specified intervals surrounding the closing date to comply with the provisions of both the Truth in Lending Act...more

OCC Outlines its 2016 Operating Plan to Set Forth the Agency’s Supervision Priorities and Objectives

The Office of the Comptroller of the Currency (OCC) released its bank supervision operating plan for fiscal year 2016 on September 25th. The operating plan sets forth the agency’s supervision priorities and objectives as...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

Montana Temporarily Reduces Licensing Renewal Fees

Montana has adopted a temporary rule to reduce certain licensing renewal fees by 50 percent for the period of January 1, 2016 through December 31, 2016. The Department of Administration believes that adopting the Uniform...more

The Consumer Financial Protection Bureau: What Insurers Should Know

Q: When does the Consumer Financial Protection Bureau (CFPB) have authority over insurance ?companies? The federal legislation commonly known as the Dodd-Frank Wall Street Reform Act, which created the ?CFPB,...more

Real Estate News - August 2015

Coming Soon… New Closing (no, Consummation…) Rules! Now Starting October 3, 2015 Instead of August 1, 2015 - What?! We can’t call it a closing anymore? Under new federal regulations regarding the Truth in Lending Act...more

CFPB Examination Resource Guide

CFPB has explained to industry participants what to expect in examinationss, both in terms of exam process and covered laws & regs. SUPERVISION AND EXAMINATION MANUAL – VERSION 2.0 First issued in 10/2011, revised &...more

Coming Soon... New Closing (no, Consummation...) Rules!

What?! We can’t call it a closing anymore? Under new federal regulations regarding the Truth in Lending Act (“TILA”) and the Real Estate Settlement Procedures Act (“RESPA”), the terminology for a “closing” or “settlement” is...more

The CFPB and the Business of Insurance: An Analysis of the Scope of CFPB’s Authority Over Insurance Sales

In 2014, the Bureau of Consumer financial Protection (CFPB) issued an enforcement order against a bank and its service provider for allegedly misleading sales of insurance. That order was based on the CFPB’s power to prohibit...more

OCC Identifies Safety and Soundness Risks to National Banks and Federal Savings Associations and Supervisory Priorities

A new report issued by the federal Office of the Comptroller of the Currency (OCC) identifies top safety and soundness risks to national banks and federal savings associations, as well as OCC supervisory priorities for the...more

FDIC Revises Examination Procedures To Incorporate TILA/RESPA Integrated Disclosures

The FDIC has revised its interagency examination procedures to reflect the requirements of the TILA/RESPA integrated disclosures (TRID) rule. The CFPB has issued a proposal to postpone the TRID rule’s effective date from...more

CFPB Delays Implementation of New TRID Form

For the second time in recent weeks, the Consumer Financial Protection Bureau (CFPB) delayed the launch of the new integrated disclosures for residential mortgage loans under the Truth in Lending Act (TILA) and Real Estate...more

CFPB’s TRID Rule Delayed Again – Uncertainty Persists for Good-Faith Grace Period

The CFPB announced on June 17 that it would delay the effective date of the “Know Before You Owe” rule until October 1, 2015. However, the proposed rule issued by the Bureau on June 25 now delays the effective date to...more

CFPB Delays Implementation of TRID

On June 24, the Consumer Financial Protection Bureau (CFPB) issued a proposed amendment to delay the effective date of the TILA-RESPA Integrated Disclosure Act, also known as the Know Before You Owe mortgage disclosure rule,...more

Dodd-Frank News: June 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

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