The CFPB recently announced that it has entered into a consent order with Lobel Financial Corporation, a company that purchases and services retail installment sales contracts (RISC) originated by subprime auto dealers, to...more
A group of 24 Democratic state attorneys general and the D.C. attorney general have submitted a comment letter to the CFPB setting forth their opposition to the CFPB’s proposal to delay the compliance date for the...more
3/22/2019
/ Ability-to-Repay ,
Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Financial Services Industry ,
Online Marketplace Lending ,
Payday Lending Rule ,
Payday Loans ,
Regulatory Agenda ,
Rulemaking Process ,
Title Loans ,
UDAAP
House Financial Services Committee Maxine Waters has announced a series of hearings for next month, including one entitled “Putting Consumers First? A Semi-Annual Review of the Consumer Financial Protection Bureau” scheduled...more
The CFPB’s proposal to revise its final payday/auto title/high-rate installment loan rule to rescind the rule’s ability-to-repay (ATR) provisions in their entirety and its proposal to delay the compliance date for the ATR...more
2/14/2019
/ Ability-to-Repay ,
Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Federal Register ,
Online Marketplace Lending ,
Payday Loans ,
Regulatory Agenda ,
Rulemaking Process ,
Title Loans
The CFPB’s Fall 2018 rulemaking agenda has been published by the Office of Information and Regulatory Affairs (OIRA) as part of its Fall 2018 Unified Agenda of Federal Regulatory and Deregulatory Actions. (OIRA is part of...more
10/18/2018
/ Abusive Acts ,
Automotive Loans ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reports ,
Debt Collection ,
Deregulation ,
Dodd-Frank ,
ECOA ,
HMDA ,
OIRA ,
Payday Lending Rule ,
Payday Loans ,
Regulation C ,
Regulation E ,
Regulatory Oversight ,
Regulatory Reform ,
Regulatory Requirements ,
Rulemaking Process ,
Title Loans
The CFPB’s newly-released Summer 2018 edition of Supervisory Highlights represents the CFPB’s first Supervisory Highlights report covering supervisory activities conducted under Acting Director Mick Mulvaney’s leadership. ...more
9/12/2018
/ Automotive Loans ,
Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Protection Laws ,
Credit Cards ,
Debt Collection ,
ECOA ,
Financial Services Industry ,
Mortgage Servicers ,
Mortgages ,
Payday Loans ,
Regulatory Oversight ,
Small Business Loans ,
Supervisory Highlights ,
Title Loans ,
Transparency
The American Banker has reported that last week, Senator Lindsey Graham introduced a joint resolution under the Congressional Review Act (CRA) to override the CFPB’s final payday/auto title/high-rate installment loan rule...more
3/27/2018
/ Ability-to-Repay ,
Administrative Procedure Act ,
Automotive Loans ,
Banking Sector ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Joint Resolutions ,
Legislative Agendas ,
Legislative Committees ,
Online Marketplace Lending ,
Payday Loans ,
Regulatory Oversight ,
Title Loans
Politico has reported that Republican Senator Jerry Moran has introduced a resolution under the Congressional Review Act (CRA) to overturn the CFPB’s 2013 auto finance guidance....more
The New York City Department of Consumer Affairs (DCA) has proposed new rules for used car dealers that would require dealers to provide the following disclosures to buyers...more
Mick Mulvaney, President Trump’s appointee as CFPB Acting Director, plans to make the CFPB’s practices of “pushing the envelope” and “rulemaking by enforcement” things of the past. ...more
1/25/2018
/ Automotive Loans ,
Banking Sector ,
CFPB Bulletins ,
Civil Investigation Demand ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Deregulation ,
Dodd-Frank ,
ECOA ,
Enforcement Actions ,
Financial Regulatory Reform ,
Regulatory Agenda ,
Regulatory Burden ,
Regulatory Oversight ,
Rulemaking Process
A new CFPB report, “Growth in Longer-Term Auto Loans”, discusses a CFPB finding that there has been a significant increase in the use of longer-term “auto loans” since 2009. ...more
In May 2017, we blogged about press reports that the Government Accountability Office (GAO) had accepted a request from Senator Patrick Toomey for a determination concerning whether the CFPB Bulletin 2013-02, titled “Indirect...more
10/27/2017
/ Add-ons ,
Administrative Procedure Act ,
Automotive Loans ,
Banking Sector ,
CFPB Bulletins ,
Congressional Review Act ,
Consumer Financial Products ,
Consumer Lenders ,
Credit Reports ,
Debt Collection ,
ECOA ,
Fair Lending ,
Financial Institutions ,
Financial Services Industry ,
GAO ,
Interagency Guidance ,
Interest Rates ,
Leveraged Lending ,
Regulation B ,
Regulatory Oversight
The CFPB has published a notice in the Federal Register announcing that a meeting of its Consumer Advisory Board will be held in Tampa, Florida on November 2, 2017....more
Earlier yesterday, at the Practicing Law Institute’s (“PLI”) 22nd Annual Consumer Financial Services Institute in New York City, Alan Kaplinsky (who is co-chairing the event) moderated a panel entitled “The CFPB Speaks,” that...more
3/28/2017
/ Administrative Law Judge (ALJ) ,
Automotive Loans ,
Banking Sector ,
CashCall ,
Constitutional Challenges ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Dodd-Frank ,
ECOA ,
Enforcement Actions ,
Financial Services Industry ,
PHH Corp. v CFPB ,
Removal For-Cause ,
Single Director ,
Tribal Loans ,
True Lender
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
1/23/2017
/ Ability-to-Repay ,
American Bankers Association ,
American Bar Association (ABA) ,
Annual Percentage Rate (APR) ,
Automotive Loans ,
Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Online Marketplace Lending ,
Payday Loans ,
Regulation Z ,
Title Loans
The CFPB has unveiled “Consumer Credit Trends,” which it describes as “a web-based tool to help the public monitor developments in consumer lending and forecast potential future risks.”...more
12/16/2016
/ Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Cards ,
Financial Institutions ,
Financial Services Industry ,
Mortgage Loan Originators ,
Mortgages ,
Risk Assessment ,
Student Loans ,
Websites
The CFPB’s Fall 2016 rulemaking agenda has been published as part of the Fall 2016 Unified Agenda of Federal Regulatory and Deregulatory Actions. The preamble indicates that the information in the agenda is current as of...more
12/2/2016
/ Advances ,
Arbitration ,
Automotive Loans ,
Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Data Collection ,
Debt Collection ,
Debt Collectors ,
ECOA ,
FDCPA ,
Financial Institutions ,
Minority-Owned Businesses ,
Mortgages ,
Overdraft Fees ,
Payday Loans ,
Regulation C ,
Regulatory Agenda ,
SBREFA ,
Small Business ,
Small Entity Representatives (SERs) ,
Student Loans ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Title Loans ,
Trump Administration ,
Women-Owned Businesses
The CFPB announced that it has entered into a consent order with TMX Finance, LLC to settle allegations that the company did not provide sufficient information to consumers about the terms of auto title loans, pawns or...more
9/27/2016
/ Advertising ,
Automotive Industry ,
Automotive Loans ,
Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Contract Terms ,
Debt Collection ,
Disclosure Requirements ,
Title Loans ,
Truth in Lending Act (TILA)
The CFPB announced that it has filed administrative enforcement actions against five Arizona auto title lenders for alleged violations of Truth in Lending Act advertising requirements. According to the CFPB, the lenders...more
9/23/2016
/ Advertising ,
Automotive Industry ,
Automotive Loans ,
Banking Sector ,
Comment Period ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Interest Rates ,
Online Marketplace Lending ,
Payday Loans ,
Title Loans ,
Truth in Lending Act (TILA) ,
Websites
By a vote of 30-26 earlier this week, the House Financial Services Committee approved the “The Financial CHOICE Act of 2016” (H.R. 5983), the bill released in July 2016 by Committee Chairman Jeb Hensarling to replace the...more
9/15/2016
/ Arbitration ,
Arbitration Agreements ,
Automotive Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Financial Services Committee ,
Financial Services Industry ,
Legislative Agendas ,
Native American Issues ,
Online Marketplace Lending ,
Payday Loans ,
Proposed Legislation ,
Regulatory Oversight ,
Tribal Loans
To commemorate its fifth anniversary, the CFPB released a series of “fact sheets” touting its initiatives. The “fact sheets” consist of the following:
CFPB: By the numbers. The CFPB lists various statistics, such as...more
7/26/2016
/ Automotive Loans ,
Banking Sector ,
Banks ,
Civil Monetary Penalty ,
Consumer Complaint Management ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
Debt Relief ,
Discriminatory Lending Practices ,
Enforcement Actions ,
Mortgages ,
Popular ,
RESPA ,
Student Loans
In its Summer 2016 Supervisory Highlights, which covers supervision work generally completed between January and April 2016, the CFPB highlights violations found by its examiners involving automobile origination, debt...more
7/6/2016
/ Automotive Loans ,
Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
Debt Collection ,
ECOA ,
EFTs ,
Fair Credit Reporting Act (FCRA) ,
Fair Lending ,
Financial Institutions ,
HMDA ,
Mortgage Loan Originators ,
Mortgages ,
Regulation B ,
Regulation V ,
Regulation X ,
Regulation Z ,
RESPA
The CFPB has issued its June 2016 complaint report which highlights complaints about consumer loans and complaints from consumers in Arkansas and the Little Rock metro area. The CFPB began taking consumer loan complaints in...more
7/1/2016
/ Automotive Loans ,
Banking Sector ,
Consumer Complaint System ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Debt Collection ,
Mortgage Servicers ,
Online Marketplace Lending ,
Payday Loans ,
Student Loans ,
Title Loans
The Independent Community Bankers of America and the Credit Union National Association have sent a letter to Director Cordray “to express serious concerns” about the CFPB’s proposed rule covering single-payment payday and...more
6/30/2016
/ Ability-to-Repay ,
Automotive Loans ,
Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Credit Unions ,
Independent Community Bankers of America (ICBA) ,
Online Marketplace Lending ,
Payday Loans ,
Title Loans
The CFPB has unveiled its latest “Know Before You Owe” initiative aimed at consumers shopping for an auto loan. The new initiative was accompanied by the CFPB’s release of a report entitled “Consumer Voices on Automobile...more