The Consumer Financial Protection Bureau, through its announcement on September 17 of the “larger participant” rule for auto lenders, has made clear that it intends to tighten its regulatory grip on the auto lending industry in the United States. In a separate special “Supervisory Highlights” report, also issued on September 17,
Consumer Financial Protection Bureau (CFPB)
CFPB Proposes Regulations Defining Larger Participants in Auto Finance Market
On September 17, the Consumer Financial Protection Bureau issued proposed regulations that amend the CFPB’s existing regulations defining “larger participants” of consumer financial products it supervises by adding a new section to define larger participants of a market for automobile financing. The CFPB explains that the approximately 38 nonbank larger participants that would be captured…
Cordray to Speak at CFPB’s Auto Finance Field Hearing on September 18
The CFPB recently announced via blog post that it will hold a “field hearing” on auto finance in Indianapolis on September 18 at 11:00AM. The announcement indicates that additional details will follow, but that the hearing will include remarks from CFPB Director Richard Cordray, and that consumer groups, industry representatives, and the public are invited…
CFPB and Federal Reserve Announce Increases in Exemption Thresholds for TILA and CLA
On September 9, the Consumer Financial Protection Bureau and the Federal Reserve Board announced increases in the dollar thresholds in Regulation Z (Truth in Lending (TILA)) and Regulation M (Consumer Leasing Act (CLA)) for exempt consumer credit and lease transactions. According to the Federal regulators, these increases are consistent with the Dodd-Frank Act and reflect…
CFPB Issues Bulletin to Credit Card Issuers on Deceptive Interest-Rate Promotions
On September 3, the Consumer Financial Protection Bureau issued a new bulletin warning credit card issuers against certain interest-rate promotions that, it claimed, posed a risk of deceptive or abusive conduct. The transactions at issue involve solicitations that “offer a promotional annual percentage rate on a particular transaction over a defined period of time” and…
CFPB Announces New Leadership
On August 28, the Consumer Financial Protection Bureau announced several new senior leaders within the organization, including:
- Patricia McClung, assistant director for mortgage markets. Prior to the CPFB, McClung worked at the Federal Housing Administration as a senior housing policy advisor.
- Janneke Ratcliffe, assistant director for financial education. Since 2005, Ratcliffe has served
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Virginia Creditors Bar Association 5th Annual Collections Seminar
On October 1, 2014, in Williamsburg, VA, the Virginia Creditors Bar Association is hosting their Fifth Annual Collections Seminar. This event will feature comprehensive discussions on issues pertaining to Creditors’ Rights and Collections Law throughout the Commonwealth of Virginia, including, but not limited to, presentations regarding bankruptcy, authenticating business records, FDCPA defense, the CFPB, and…
Twelve Participants Chosen for CFPB Mortgage Closing Pilot Project
On August 21, the Consumer Financial Protection Bureau (CFPB) has selected seven mortgage companies and five vendors to participate in a three-month pilot program that will aim to determine whether electronic filings could improve mortgage closings. The pilot program is a part of the CFPB’s “Know Before You Owe” mortgage initiative.
Earlier this year in…
Potential Expansion of HMDA Reporting Requirements
The Consumer Financial Protection Bureau has published proposed changes to Regulation C, which implements the Home Mortgage Disclosure Act (HMDA). The HMDA was enacted by Congress in 1975, and on July 21, 2011, the rule-writing authority of Regulation C was transferred to the CFPB. HMDA requires covered depository and nondepository institutions to collect and publicly…
Amerisave to Pay $19.3 Million for Bait-and-Switch Mortgage Scheme
On August 12, the Consumer Financial Protection Bureau issued an order related to the advertising of mortgage rates that may provide valuable insight into the CFPB’s broader perspective on what constitutes misleading statements in advertising and publishing of rates.
The CFPB accused Amerisave Mortgage Corporation (“Amerisave”), its affiliate company Novo Appraisal Management Company (“Novo”), and…