Bank Notes

  • July 29, 2016
    On Friday, July 29, 2016, the FDIC issued a request for comments on updates to its guidelines for institutions to appeal certain material supervisory determinations. The agency also seeks comments on draft guidance regarding third-party lending. The two items are part of a package issued by the FDIC Board of Directors aimed at improving transparency and clarity of the FDIC's supervisory policies...
  • July 29, 2016
    On Friday, July 29, 2016, the CFPB issued a proposal to amend the TILA-RESPA Disclosure (TRID) Rule in order to formalize guidance and for technical changes. Comments on the proposal are due on October 18, 2016. The proposed amendments include: Tolerances for Total Payments : The Bureau proposed including tolerances for the “total of payments” calculation to mimic the finance charge tolerances...
  • July 29, 2016
    On Friday, July 29, 2016, the CFPB announced a proposed change to its complaint closing process. Instead of disputing a company’s response to a complaint not fully resolved to the consumer’s satisfaction, the CFPB has proposed a survey including a five point rating and narrative option. This proposal is in response to consumer groups’ comments on the Bureau’s March 2015 request for information...
  • July 28, 2016
    On Thursday, July 28, 2016, the CFPB held a field hearing in Sacramento, CA on debt collection reforms. The Bureau also released an outline of proposals for third-party debt collectors as well as a study on its operations. The outline will be the subject of a forthcoming Small Business Regulatory Enforcement Fairness Act (SBREFA) panel for debt collectors and debt buyers. The Bureau is expected...
  • July 27, 2016
    On Wednesday, July 27, 2016, the CFPB Ombudsman’s Office issued its mid-year update for FY 2016, providing a brief snapshot of some of its work in advance of the Office’s November Annual Report. The update outlines the office’s significant issues including ex parte communications procedures and the consumer complaint database. Regarding CFPB Proposed Rules, the Ombudsman’s Office addressed...
  • July 26, 2016
    On Tuesday, July 26, 2016, the CFPB released its Monthly Complaint Report for June, spotlighting complaints in Seattle and other parts of Washington state as well as credit card complaints. As of July 1, 2016, the Bureau has handled approximately 930,700 total complaints and approximately 97,100 credit card-related complaints. For June, the most complained about product or service was debt...
  • July 25, 2016
    On Monday, July 25, 2016, the D.C. Circuit Court of Appeals ordered the oral arguments in CBA’s Telephone Consumer Protection Act case against the FCC, consolidated as ACA International v. FCC , be heard on October 19, 2016. The composition of judges on the panel will be released 30 days prior to oral argument.
  • July 22, 2016
    On Friday, July 22, 2016, the Federal Reserve Board, OCC and CFPB issued a joint proposal detailing the method to be used in making annual inflation adjustments to the threshold for exempting small loans from higher priced mortgage loan appraisal requirements. The Dodd-Frank Act amended the Truth in Lending Act to add special appraisal requirements for higher-priced mortgage loans, including a...
  • July 22, 2016
    On Friday, July 22, 2016, the Federal Reserve Board and the CFPB issued a proposal detailing the method to be used to adjust the thresholds for exempting certain consumer credit and lease transactions from the Truth in Lending and Consumer Leasing Acts. The Dodd-Frank Act requires the exemption thresholds in the Truth in Lending Act (TILA) and the Consumer Leasing Act (CLA) be adjusted annually...
  • July 21, 2016
    On Thursday, July 21, 2016, Sens. Sherrod Brown (D-OH) and Jeff Merkley (D-OR) sent a letter to financial regulators calling on them to provide more information on how they are ensuring effective oversight of Fintech companies. The letter was addressed to the heads of the Federal Reserve, OCC, the FDIC, the National Credit Union Administration, and the CFPB. To better understand how federal...

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