Search Results: test CFPB

CFPB Director Proposes to Supervise "Captive" Auto Finance Companies

On September 18, CFPB Director Richard Cordray delivered remarks at a Field Hearing about CFPB’s latest proposed rule, which would allow it to begin regulating “captive” finance companies – those entities owned by automotive manufacturers “for the primary purpose of facilitating sales for their parent companies and associated dealers.” In his…

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Interagency Guidance: Regulators Will Enforce UDAAP Laws Notwithstanding Repeal of Regulation AA

The Federal Reserve Board recently made headlines when it repealed its Regulation AA to comply with the Dodd-Frank Act, leading some to wonder how, and to what extent, regulation of financial institutions might change going forward. But the federal agencies charged with regulating banking and credit activities have made it clear that they will continue to enforce prohibitions…

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GAO Report: Consumer Protections Against Virtual Currency Risks Still Lacking; CFPB Should Step In

On June 26, 2014, the Government Accountability Office (GAO) issued a report entitled “Virtual Currencies: Emerging Regulatory, Law Enforcement, and Consumer Protection Challenges.”  The report discusses the benefits and disadvantages of virtual currency and reviews efforts to date by federal agencies to regulate the virtual currency market.  The report concludes…

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Committee of Banking Regulators Begins Cyber-Security Assessments of 500 Financial Institutions

On June 24, 2014, in response to the “increasing volume and sophistication of cyber threats,” the Federal Financial Institutions Examination Council (“FFIEC”) began a month-long cyber-security assessment of 500 community financial institutions and credit unions.  Announcing what it dubbed a “pilot program,” the FFIEC—a formal, interagency body made up of…

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Recent DOJ & CFPB Consent Orders Highlight ECOA Risks For Servicers

Synchrony Bank (formerly known as GE Capital Retail Bank) made two direct mail offers to its credit card holders, but it did not send the offers to Spanish-speaking customers.  The Bank self-reported its actions, resulting in consent orders with the Consumer Financial Protection Bureau and the Department of Justice, which…

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Mobile Banking in the 21st Century: More Freedom for Consumers, More Red Tape for Financial ...

On June 11, as a result of the growing use of mobile banking services across the country, the CFPB announced that it was conducting a request for information into the benefits and consequences of expanding mobile financial services.  Its focus is underserved and remote communities, but any actions the CFPB…

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CFPB Targets NonBank Compliance Plans

On May 22, the CFPB released its fourth “Supervisory Highlights” publication, giving financial services providers a preview of the CFPB’s future enforcement priorities. This edition drew attention to regulatory compliance in nonbank financial entities like debt collectors, payday lenders, and consumer credit reporting firms. While those industries have been subject to…

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New CFPB Amendments Require Prompt Servicer Response to Borrower Complaints and Requests for ...

On January 10, 2014, new CFPB amendments to Regulation X (implementing the Real Estate Settlement Procedures Act) and Regulation Z (implementing the Truth in Lending Act) became effective, imposing new requirements on loan servicers to respond to inquiries from residential mortgage loan borrowers within statutorily-specified time periods. An understanding of…

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