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Nevertheless, the Bureau’s new exam manual clearly signaled that the Bureau will examine targeted advertising. Conclusion. The CFPB’s announcement is a sea change in how financial institutions need to think about fair lending and fair treatment. By expanding both the product and activity reach of anti-discrimination enforcement, the CFPB
The American Bankers Association and six other trade groups today sued the Consumer Financial Protection Bureau and Director Rohit Chopra for exceeding the agency’s legal authority in a March update to the UDAAP exam manual, in which the bureau expanded the statutory definition of “unfairness” to encompass discrimination. In their lawsuit
The CFPB began to accept complaints about credit cards, mortgages, consumer loans and other products in 2011 and released the consumer complaint database (CCD) publicly last year. “The public database created a new risk dynamic for covered firms,” said Mr. Kiefer. “There are particular challenges regarding mortgages, and communication with consumers may be important.” With more than 118,000
At least $8 billion of private student loans are in default, roughly 5% of the $150 billion market, according to an annual report released in October by the CFPB’s student loan ombudsman. The Student Lending Examination Procedures is a part of the CFPB’s General Supervision and Examination Manual. The procedures will be used in examining both
Credit unions can find more information about the affected products on the NCUA’s Consumer Compliance Regulatory Resources page. Please contact the Office of Consumer Financial Protection at 703.518.1140 or by email at ComplianceMail@ncua.gov if you have questions. You can also contact your NCUA regional office or your state supervisory authority.
On February 14, the Consumer Financial Protection Bureau (CFPB) updated its Supervision and Examinations Manual to reflect changes it made to the Remittance Transfer Rule (Rule) in a final rule published on June 5, 2020. The changes made to Subpart B of Regulation E, effective July 21, 2020, (1) increased the Rule’s safe harbor for compliance from 100 remittance transfers to 500 remittance
The Consumer Financial Protection Bureau (CFPB or Bureau) recently released its Spring Supervisory Highlights summarizing findings from supervisory exams it conducted between July and December 2021.. The CFPB has made various statements and numerous public-facing communications, including the Supervisory Highlights document, about its mission and priorities.
On March 16, the CFPB “conflated the concepts by announcing, via a UDAAP exam manual ‘update,’ that it would examine financial institutions for alleged discriminatory conduct that it deemed to be ‘unfair’ under its UDAAP authority,” the groups wrote. The change is “contrary to law and subject to legal challenge” as well as potential congressional action, the groups added.
Credit Card Activities Manual – PDF. Chapter I. – Introduction. Chapter II. – Credit Cards – General Overview. Chapter III. – Identifying Involvement in Credit Card Activities. Chapter IV. – Credit Card Program Development. Chapter V. – Marketing and Acquisition. With the recess appointment of the director of the Consumer Financial Protection Bureau, the agency is becoming even more active and issues are coming into focus. Financial institutions subject to its jurisdiction should pay attention to its Supervision and Examination Manual published in late 2011.
The CFPB has updated its exam manual for evaluating UDAAPs, which notes that discrimination may meet the criteria for “unfairness” by causing substantial harm to consumers that they cannot reasonably avoid, where that harm is not outweighed by countervailing benefits to consumers or competition.
The CFPB has updated its exam manual for evaluating UDAAPs, which notes that discrimination may meet the criteria for “unfairness” by causing substantial harm to consumers that they cannot reasonably avoid, where that harm is not outweighed by countervailing benefits to consumers or competition.
The American Bankers Association is the voice of the nation’s $23.7 trillion banking industry, which is composed of small, regional and large banks that together employ more than 2 million people, safeguard $19.6 trillion in deposits and extend $11.8 trillion in loans. In Depth Compliance Consumer Banking Press Contact Josh Britton (202) 663-7553
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