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CFPB: Proposal to Amend the 2013 Rule Implementing CFPA The Consumer Financial Protection Bureau is proposing to amend its 2013 rule implementing the provision of the Consumer Financial Protection Act of 2010 that establishes a Consumer Financial Civil Penalty Fund (Civil Penalty Fund)
Truth in Lending Act (Reg Z) - American Bankers Association Truth in Lending Act (Reg Z) TILA promotes the informed use of consumer credit by requiring timely disclosure about its costs It also includes substantive provisions such as the consumer’s right of rescission on certain mortgage loans and timely resolution of billing disputes
Unfairness and Discrimination - American Bankers Association And perhaps most shocking is that it completely ignores the need for “robust causality,” which requires a “direct relation between the injury asserted and the injurious conduct alleged ”85 The CFPA’s definition of unfairness requires a minimal causal relation between the act or practice and consumer harm
Letter to CFPB re 1034(c) Advisory Opinion - American Bankers Association Although the CFPB frames its advisory opinion as interpreting 1034(c), that provision is silent regarding fees, customer service, and other issues The advisory opinion imposes new prohibitions and standards that are not expressed or implied in text of the statute and are inconsistent with the agency’s interpretation of other laws
A Conversation with the CFPB on Operationalizing 1071 – What Did We . . . On March 30, 2023, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a final rule amending its regulations that implement the Equal Credit Opportunity Act (“ECOA”) pursuant to Section 1071 of the Dodd-Frank Wall Street Reform and Protection Act (“Dodd-Frank”) [1] Section 1071 requires covered financial institutions to collect and report data on loan
Letter to the CFPB on Registry of Nonbank Covered Persons Subject to . . . The Consumer Financial Protection Act (CFPA) clearly exempts insured depository institutions from the CFPB's registration authority, stating, " [t]he Bureau may prescribe rules regarding registration requirements applicable to a covered person other than an insured depository institution, insured credit union, or related persons "
What Did We Hear? - American Bankers Association To facilitate information exchange and further knowledge sharing, Wolters Kluwer welcomed the CFPB to a well-attended webinar in late April to discuss operationalizing the new 1071 rule As the industry continues to read and digest the 888-page rule, Wolters Kluwer sought a dialogue with the CFPB that did more than just summarize 1071, but rather fleshed out ideas to ensure lender compliance