In 2012, the Consumer Financial Protection Bureau (“CFPB”) launched its Project Catalyst initiative, which is dedicated to promoting consumer-friendly innovation in the financial services marketplace. The CFPB explains the initiative’s work as outreach and collaboration with a variety of institutions to develop new programs, perform research, and conduct disclosure testing, among other projects. On October […]

As financial institutions grapple with data security and risk management issues, the Federal Financial Institutions Examinations Council’s (“FFIEC”) Cybersecuity Assessment Tool (“CAT”) has become an important component of monitoring cybersecurity risk. However, the CAT is largely presented as a series of tables, risk levels, and statements that understandably give rise to questions. Now, the FFIEC […]

Today, the Independent Community Bankers Association (“ICBA”), a trade group representing the community banking industry, filed a lawsuit challenging new rules permitting credit unions to make additional types of commercial loans. The ICBA asserts that the National Credit Union Administration, which regulates credit unions and recently issued the federal regulation in dispute, violated its rule-making […]

Last week, the Consumer Financial Protection Bureau (“CFPB”) published an informational guide to help settlement professionals navigating the changes that are a part of the Know Before You Owe mortgage initiative. After months of preparation, the TRID Rule became effective last fall, with the promise to help consumers make informed decisions about mortgage choices. Since […]

As institutions continue to work through integration of the TILA-RESPA Integrated Disclosure (“TRID”) and face questions regarding its application and unique factual scenarios, they should be aware of a resource the CFPB has compiled. Over the last 10 months, the Federal Reserve Board has hosted several webinars, all of which are available on the Internet. […]

Recently, the Consumer Financial Protection Bureau (“CFPB”) issued its annual adjustments to the dollar amounts of various thresholds under the Truth in Lending Act (“TILA”), effective January 1, 2017. In addition, the CFPB corrected a calculation error pertaining to the 2016 subsequent violation penalty safe harbor fee. Specifically, the CFPB’s action adjusted the dollar amounts […]

In Spokeo v. Robins, No. 13-1339, the Supreme Court of the United States delivered a somewhat underwhelming decision in a case challenging a consumer’s right to sue under the Fair Credit Reporting Act (“FCRA”) without any actual damages. The consumer, Thomas Robins, asserted that Spokeo published incorrect and false information about him on its online […]

The Consumer Financial Protection Bureau (“CFPB”) has issued additional resources related to the CFPB’s mortgage servicing rules. The first, a fact sheet, summarizes key issues for small creditors operating in a rural or underserved area. This fact sheet includes information related to verifying small creditors’ official designation under the mortgage servicing rules. This document also […]

Recently, the Consumer Financial Protection Bureau (“CFPB”) issued an interim final rule (“Rule”) that expanded “qualified mortgage” coverage in rural or underserved areas. Specifically, the Rule amends certain provisions of Regulation Z, the implementing regulations of the Truth-in-Lending Act. The updates concern two issues. First, the Rule expands the eligibility of certain small creditors operating […]

This week, the Federal Deposit Insurance Corporation (“FDIC”) clarified its supervisory expectations for how institutions should handle decisions to discontinue foreclosure proceedings that are underway, commonly referred to as abandoned foreclosures. Although not all institutions fall into the FDIC’s supervisory scope, prudential regulators and examiners often address practical problems (such as foreclosures) similarly. In the […]