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Bank Regulators Issue Statement on Third-Party Relationships with Financial Institutions and Publish Request for Information on...

The federal banking regulators (The Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Federal Deposit Insurance Corporation) issued on July 25 a lengthy joint statement...more

CFPB Proposes Interpretive Rule that EWAs Are Credit; Expedited Funding Fees and Tips May Be Finance Charges under Regulation Z

On July 18, 2024, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) proposed an interpretive rule that states (1) EWA products fall under the definition of “credit” under the Truth in Lending Act (“TILA”) and...more

FTC extends comment deadline for “junk fees” proposal

The FTC has extended by 30 days the deadline for submitting comments on its proposed “Rule on Unfair or Deceptive Fees” targeting what the FTC refers to as “junk fees.”  The new comment deadline is February 7, 2024....more

CFPB seeks comment on new survey of student loan borrowers

The CFPB has published a notice in the Federal Register seeking comment on its request for approval by the Office of Management and Budget of a new one-time survey of student loan borrowers.  Comments must be received by...more

CFPB proposes significant changes to credit card late fee rules, including reduction in late fee safe harbor amounts and...

We suspected something was afoot when December 2022 came and went without the CFPB announcing its annual inflation adjustments to the credit card late fee safe harbor amounts set forth in Regulation Z (which implements the...more

California DFPI releases modified proposed Student Loan Servicing Act regulations

On September 9, 2022, the California Department of Financial Protection and Innovation (DFPI) proposed to amend its student loan servicing regulations, which we previously covered  here.  After reviewing public comments, on...more

CFPB considering changes to semi-annual credit card survey

The CFPB is seeking comments on changes to its semi-annual Terms of Credit Card Plans (TCCP) Survey. Comments must be submitted by October 17, 2022....more

CFPB issues request for information on relationship banking and customer service

The CFPB has issued a request for information (RFI) that seeks comments from the public “on what customer service obstacles consumers face in the banking market, and specifically what information would be helpful for...more

FTC seeks comment on whether to continue Telemarketing Sales Rule business-to-business exception and proposes amendments

The Federal Trade Commission issued two notices this week concerning the Telemarketing Sales Rule (TSR)—an advance notice of proposed rulemaking (ANPR) and a notice of proposed rulemaking (NPR). Both notices address the...more

CA DFPI proposes rule to require registration of consumer financial services providers

The California Department of Financial Protection and Innovation (DFPI) is seeking comments on a proposed rulemaking under the California Consumer Financial Protection Law (CCFPL). The proposal would implement the authority...more

CFPB Issues Request For Information On Consumer Credit Card Market

The CFPB has issued a new request for information about the credit card market that seeks comment on two related, but separate, reviews. One review is a review of CARD Act rules pursuant to Section 610 of the Regulatory...more

HUD publishes proposed revisions to disparate impact rule

HUD’s proposed revisions to its disparate impact rule were published in today’s Federal Register.  Comments on the proposal are due on or before October 18, 2019. ...more

NY Dept. of Financial Services issues proposed student loan servicer regulations

The New York Department of Financial Services (NYDFS) has issued proposed regulations to implement the legislation enacted in April 2019 that requires servicers of student loans to be licensed, imposes servicing standards,...more

FCC votes to approve call blocking declaratory ruling and adopts NPRM on caller ID authentication

The FCC announced that it has approved the declaratory ruling previously circulated by Chairman Pai that would allow voice service providers to start offering default call-blocking programs that are based on reasonable...more

CFPB publishes debt collection proposed rule

The CFPB has published its long-awaited notice of proposed rulemaking under the Fair Debt Collection Practices Act (FDCPA). ...more

CFPB issues request for information for next CARD Act review

The CFPB published a request for information in yesterday’s Federal Register seeking information to inform its next review of the credit card market.  The CARD Act requires the Bureau to conduct such a review every two...more

OCC seeks comment on modernizing CRA regulatory framework

The Office of the Comptroller of the Currency (OCC) has issued an advance notice of proposed rulemaking (ANPR) on which it invites public comment “to solicit ideas for building a new framework to transform or on ways to...more

CFPB seeks comment on public reporting of consumer complaint information

The CFPB has issued a request for information that seeks comment on potential changes to the CFPB’s practices for the public reporting of consumer complaint information. ...more

CFPB submits request to conduct online debt collection survey to OMB

The CFPB has published a notice in the Federal Register that it has submitted to OMB its request to conduct an online survey of 8,000 individuals as part of its research on debt collection disclosures. Comments must be...more

FHFA announces reopening and second extension of comment period for LEP RFI

The Federal Housing Finance Agency has announced that it has reopened and extended until September 1, 2017 the comment period on its Request for Input on improving language access in mortgage lending and servicing.  The FHFA...more

FHFA extends comment period for LEP RFI

The Federal Housing Finance Agency has announced that it has extended until July 31, 2017 the comment period on its Request for Input on improving language access in mortgage lending and servicing....more

Industry groups ask FHFA to extend comment period for LEP RFI

A group of eight trade associations has sent a letter to the Federal Housing Finance Agency (FHFA) asking the FHFA to extend by at least 45 days the comment period on the FHFA’s Request for Input (RFI) on improving language...more

Dept. of Education postpones effective date of arbitration ban and other provisions of “borrower defense” rule, announces intent...

In a notice published in today’s Federal Register, the Dept. of Education announced that it is postponing “until further notice” the July 1, 2017 effective date of various provisions of the “borrower defense” final rule...more

FCC’s Proposed Regulations Would Gut TCPA Exception for Debts Owed to or Guaranteed by U.S.

The Bipartisan Budget Act of 2015 (Act) amended the Telephone Consumer Protection Act (TCPA) to remove the prior express consent requirement for calls ''made solely to collect a debt owed to or guaranteed by the United...more

CFPB seeking comment on new repayment plan disclosures for federal student loan borrowers

The CFPB has issued a Request for Information (RFI) seeking comment on a set of prototype disclosures to assist federal student loan borrowers in selecting between alternative repayment plans.  Comments are due on or before...more

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