Dykema Gossett PLLC
Dykema Gossett PLLC

Consumer Financial Protection Bureau Law Blog

CFPB Law Blog

News and analysisi of the priorities, initiatives and regulatory actions and proceedings of the Consumer Financial Protection Bureau

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CFPB Concludes Medical Debts Unduly Harm Credit Scores

On May 20, 2014, the Consumer Financial Protection Bureau (CFPB) issued a data point report that focused on whether consumers with medical debts were overly penalized for medical debts that go into collection and show up on their credit reports. The CFPB confronted two questions in the report: (1) “whether medical and non-medical collection are equally predictive about the subsequent respective credit performance of consumers with these different types of accounts” and (2) “whether paid and unpaid medical collections are equally predictive of consumer delinquency rates.” In assessing these questions, the CFPB reviewed about five million anonymized credit records. The answer to both questions—according to the CFPB—is no.   Read More ›

House Financial Services Subcommittee Holds Legislative Hearing on CFPB Proposals

On May 21, the House Financial Services’ Subcommittee on Financial Institutions and Consumer Credit (Chairwoman Shelley Moore Capito, R-WV) held a legislative hearing entitled “Legislative Proposals to Improve Transparency and Accountability at the Consumer Financial Protection Bureau (CFPB).” The hearing focused on eleven separate Republican proposals that would seek to curtail the CFPB’s powers and increase Congressional oversight over the agency  Read More ›

CFPB Presents Annual Fair Lending Report to Congress

On April 30, the Consumer Financial Protection Bureau (the CFPB) presented its annual Fair Lending Report to Congress.  The Fair Lending Report details the CFPB’s actions and initiatives during 2013. In particular, the Report reveals how the CFPB makes enforcement decisions and includes examples of several of the CFPB’s enforcement actions from past year.  Read More ›

CFPB Proposes Electronic Posting of Annual Privacy Notices

On May 6, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule that would amend the annual privacy notice requirement under the Gramm-Leach-Bliley Act (GLBA). Under the proposal, financial institutions would be granted the option to deliver the annually-required privacy disclosure electronically, if they meet certain other requirements. Read More ›

CFPB Proposes Changes to QM Rules

The Consumer Financial Protection Bureau (CFPB) recently announced proposed amendments to Regulation Z. Significantly, one of the three proposed amendments affects qualified mortgages (QM), which are entitled to a presumption under the Dodd-Frank Act that the creditor making the loan has satisfied the ability-to-repay requirements.    Read More ›

CFPB Issues Consumer Advisory and Sample Letters in Response to Mid-Year Report on Student Loan Complaints

The Consumer Financial Protection Bureau (CFPB) recently released a report on student loan complaints. Specifically, the report highlights complaints concerning co-signer issues on student loans. Many private student lenders advertised that their loans contained an option to release a borrower’s co-signer after a certain period of on-time payments. The complaints describe the bureaucratic obstacles borrowers are facing when seeking to obtain these releases. In addition, complaints reveal that borrowers often have to apply for a release but they are generally not provided with the criteria for co-signer release from the lenders and servicers.  Read More ›

CFPB Publishes Guide to the TILA-RESPA Loan Estimate and Closing Disclosure Forms

The Consumer Financial Protection Bureau (CFPB) on April 17, 2014 announced the release of a Guide to Completing TILA-RESPA Integrated Disclosure Forms (the Forms Guide). The CFPB states that the purpose of the Forms Guide is to provide instructions for completing the two new integrated TILA-RESPA disclosure forms, the Loan Estimate and Closing Disclosure, and to highlight common situations that may arise when completing the forms. Additionally, as the changes related to the TILA-RESPA Integrated Disclosure Rule may take time, resources, and planning to execute, the CFPB hopes the Forms Guide will help identify some of the necessary changes that may need to be implemented by organizations involved in the origination of closed-end residential mortgage loans. Settlement service providers, software providers, and other companies that serve as business partners to creditors may also find the Forms Guide helpful  Read More ›

Proposed Legislation Would Require CFPB to Create An Advisory Board for Small Financial Services Companies

On April 3, 2014, the Bureau of Consumer Financial Protection Small Business Advisory Board Act was introduced into the U.S. House of Representatives.    The bill would require the Consumer Financial Protection Bureau (CFPB) to create an advisory panel of small financial services companies.  The bill would further require the CFPB to meet regularly with small-business owners that work in the consumer finance industry and must comply with the CFPB’s regulations.  Read More ›

New Bill Would Change CFPB Information Gathering Process for Smaller Financial Institutions

A new bill, introduced on April 10th by Senator Dan Coates of Indiana, could provide smaller financial institutions relief from financial regulations enacted after the 2008 financial crisis. Read More ›

CFPB Releases Small Entity Compliance Guide for TILA-RESPA Integrated Disclosure Rule

In late March, the Consumer Financial Protection Bureau (CFPB) issued a  Small Entity Compliance Guide (Guide) for the TILA-RESPA Integrated Disclosure Rule (TILA-RESPA Rule). In compliance with Section 212 of the Small Business Regulatory Enforcement Fairness Act of 1996, the CFPB has issued the guide to help small businesses comply with the TILA-RESPA Rule, which is effective August 1, 2015. Read More ›