Bank Notes

  • April 26, 2018
    On Thursday, April 26, 2018, the CFPB finalized its amendment to its “Know Before You Owe” mortgage disclosure rule. The amendment aims to address when mortgage lenders with a valid justification may pass on increased closing costs to consumers and disclose them on a Closing Disclosure. The Know Before You Owe mortgage disclosure rule took effect Oct. 3, 2015. The Bureau’s rule created new Loan...
  • April 20, 2018
    On Friday, April 20, 2018, the CFPB, in a coordinated action with the OCC, announced a settlement with Wells Fargo Bank , after the agencies found Wells Fargo violated the Consumer Financial Protection Act through the way the bank administered its insurance program related to auto loans. Under the terms of the consent orders, Wells Fargo must pay a $1 billion penalty, with $500 million going to...
  • April 18, 2018
    On Wednesday, April 18, 2018, the CFPB released their independent audit, facilitated by KPMG LLP, which covers the period from July 18, 2017 to February 28, 2018. KPMG evaluated the CFPB’s budget process relative to its priorities and procedures established over budget formulation, execution, and monitoring; monitoring and oversight of the interagency agreement with the Bureau of Fiscal Service;...
  • April 18, 2018
    On Wednesday, April 18, 2018, the U.S. Senate passed a Congressional Review Act (CRA) Resolution, which was introduced by Jerry Moran (R-Kan.), to overturn the CFPB's 2013 Auto Bulletin. A companion bill has been introduced in the House of Representatives by Congressman Lee Zeldin (R-N.Y.) and CBA expects this resolution to pass too, thereby sending the CRA to President Donald Trump's desk for...
  • April 18, 2018
    On Wednesday, April 18, 2018, the Senate Commerce Committee held a hearing entitled "Abusive Robocalls and How We Can Stop Them." While the hearing focused on illegal robocalls, and particularly enforcement against such calls and available technology tools, CBA used the hearing as an opportunity to distinguish between robocalls and calls from legitimate businesses to their customers. CBA sent a...
  • March 28, 2018
    On Wednesday, March 28, 2018, the CFPB released its Request for Information (RFI) on the Bureau’s guidance and information support. This is the tenth in the series of RFIs aimed to ensure the Bureau is fulfilling its proper and appropriate functions, and will focus on the Bureau’s guidance materials and activities. The next RFI in this series will be released next week, and will focus on consumer...
  • March 28, 2018
    On Wednesday, March 28, 2018, the FDIC announced settlements with Cross River Bank , and its institution-affiliated party, Freedom Financial Asset Management, LLC for unfair and deceptive practices in violation of the FTC Act related to the marketing and origination of Consolidation Plus Loans. The FDIC also found the bank and its institution violated TILA and EFTA. The settlement will require...
  • March 23, 2018
    On Wednesday, March 14, 2018, the CFPB issued its Request for Information (RFI) on the Bureau’s adopted regulations and new rulemaking authorities. This is the eighth in a series of RFIs announced as part of Acting Director Mick Mulvaney’s call for evidence to ensure the Bureau is fulfilling its proper and appropriate functions to best protect consumers. The next RFI in the series will address...
  • March 22, 2018
    On Thursday, March 22, 2018, the CFPB issues its Request for Information (RFI) on the Bureau’s inherited regulations and inherited rulemaking authorities. This is the ninth in a series of RFIs announced from the Bureau in an effort to assess the overall efficiency and effectiveness of its rulemaking processes. The next RFI in the series will address the Bureau’s guidance and implementation...
  • March 20, 2018
    On Tuesday, March 20, 2018, the CFPB granted CBA extension requests. The CID comment letter is now due on April 26, the adjudication comment letter is now due on May 7, and the enforcement comment letter is now due on May 14. Please see the updated information on the following pages of the Bureau’s website: https://www.consumerfinance.gov/policy-compliance/notice-opportunities-comment/open-...

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