As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Act), enacted in 2018, directs the CFPB to prescribe regulations that apply Truth in Lending Act (TILA) ability-to-repay (ATR)...more
The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML)....more
Financial services encompass a wide range of services offered by the nation’s financial institutions, including banking, mortgage, investment, and credit services. The next administration and Congress’s financial services...more
Government reporting contains no shortage of signals that threat actors, including traditional terroristic actors, are eager to disrupt global shipping and supply chains. This threat environment of frequent negative headlines...more
This article discusses the amendments adopted by the Securities and Exchange Commission (SEC) in 2020 that modernize the offering related provisions of the Securities Act of 1933, as amended (Securities Act), and the...more
Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more
A closely divided Congress will limit financial services legislation but Biden appointees in key regulatory positions will have a large impact on the financial services policy agenda. The Biden administration is likely to...more
As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act), also known as S.2155, directs the CFPB to implement an exemption from the mandatory escrow account requirement for...more
This survey summarizes several recent developments affecting bank deposits and payment systems. These include payments-related consent orders and enforcement actions by the Consumer Financial Protection Bureau (“CFPB”) and...more
The U.S. Securities and Exchange Commission on April 8, 2020 adopted a package of reforms to the securities registration, offering and communications requirements under the Securities Act of 1933 applicable to business...more
On April 8, 2020, the Securities and Exchange Commission (the SEC) voted, at its first virtual meeting, to adopt rule amendments to implement certain provisions of the Small Business Credit Availability Act (the BDC Act) and...more
In January 2020 the Federal Housing Finance Agency (FHFA) published a request for input on Property Assessed Clean Energy (PACE) transactions involving residential property. ...more
The Nationwide Multistate Licensing System & Registry (NMLS) is scheduled to release a system enhancement on November 24, 2019, which will allow qualified mortgage loan originators (MLOs) who are changing employment from a...more
It has been almost 18 months since the passage of the Economic Growth, Regulatory Relief, and Consumer Protection Act or (as most people in the industry refer to it) the “Temporary Authority Act.” Section 106 of the act...more
On October 10, 2019, the Board of Governors of the Federal Reserve System (Board), together with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation, adopted a final rule to revise the...more
The CFPB recently published SAFE Act FAQs addressing temporary authority. The CFPB identifies the following categories of loan originators under the SAFE Act, as amended by the Economic Growth, Regulatory Relief, and...more
As we previously reported, last November the FDIC, Federal Reserve Board and Comptroller of the Currency (the federal banking agencies) proposed a rule to implement a rural residential property appraisal exemption under the...more
The CFPB recently updated two prior Home Mortgage Disclosure Act (HMDA) webinars to reflect amendments to HMDA made by the Economic Growth, Regulatory Relief, and Consumer Protection Act, and the interpretive and procedural...more
To protect veterans from loan churning, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act) imposed additional requirements for Interest Rate Reduction Refinance Loans (IRRRLs) to be guaranteed by...more
Just before adjourning for the summer district work period, 13 Republicans from the Senate Banking Committee sent a letter pushing for expedited implementation of S. 2155, the Economic Growth, Regulatory Relief, and Consumer...more
On July 22, 2019, five federal agencies (the “Agencies”) published a final rule (the “Final Rule”), which conforms the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 of...more
The Social Security Administration (SSA) has announced the development of a portal that would allow financial institutions to join a planned real-time electronic system for verifying the identity of credit applicants. ...more
Five federal financial regulatory agencies adopted a final rule to exclude community banks from the Volcker Rule, consistent with the Economic Growth, Regulatory Relief, and Consumer Protection Act....more
The Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act) enacted last year includes a provision to protect veterans from loan churning by providing, among other requirements, that a loan to a veteran...more
Part of the 2018 Economic Growth, Regulatory Relief, and Consumer Protection Act (which amended the Fair Credit Reporting Act) included a provision requiring credit reporting agencies (CRAs) to provide free electronic credit...more