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So far Think Compliance has created 184 blog entries.

CFPB updates HMDA reporting guidance

On July 19, 2017, the CFPB issued HMDA Loan Scenarios to provide additional guidance to the industry on reporting transactions under the revised HMDA rule. Most provisions from the revised rule will take effect on January 1, 2018. The guidance, which is provided as an illustrative aid to help financial institutions prepare their Home Mortgage Disclosure [...]

By | 2017-07-19T23:36:45+00:00 July 19th, 2017|0 Comments

Reactions to the CFPB’s arbitration rule

On July 10, the CFPB issued its much-anticipated final arbitration rule which prohibits covered entities from including mandatory arbitration clauses in contracts that block class-action litigation. The rule will become effective 60 days after publication in the Federal Register, but will only apply to pre-dispute arbitration agreements for covered products or services entered into on [...]

By | 2017-07-13T13:02:22+00:00 July 13th, 2017|0 Comments

What the arbitration rule means for CFPB payday rule

Earlier this week, CFPB Director Richard Cordray acknowledged the possibility that the Bureau’s arbitration rule could be rolled back by a CRA vote but claimed that he did not factor Congressional opposition into his decision to release the final rule. Cordray explained, “My obligation as the director of the consumer bureau is to act [...]

By | 2017-07-13T14:15:14+00:00 July 13th, 2017|0 Comments

CFPB issues rule prohibiting class action waivers in consumer contracts

Today, the CFPB announced that it has issued its final rule on arbitration. The Bureau also released a short video explaining the arbitration rule. The much-anticipated rule targets providers of certain consumer financial products and services, prohibiting them from using arbitration clauses in customer contracts to block consumers from participating in class action lawsuits. [...]

By | 2017-07-10T15:59:17+00:00 July 10th, 2017|0 Comments

Why the CFPB payday rule might not be coming soon

Last June, the CFPB held a field hearing in Kansas City, Missouri to announce the release of the consumer watchdog agency’s highly anticipated proposed rule covering payday and auto title loans, and certain high-cost installment loans. More than a year has passed since the notice of proposed rulemaking was issued last June, and despite [...]

By | 2017-07-12T07:52:48+00:00 July 9th, 2017|0 Comments

Do one-time debit payments made over the phone require verbal authorization?

QUESTION: Should lenders require the customer to provide verbal authorization for one-time debit card payments over the phone? Should lenders retain recordings of such authorizations? ANSWER: Regulation E does not establish requirements pertaining to authorizations for one-time EFTs, but that doesn’t mean that lenders shouldn’t have certain practices in place [...]

By | 2017-07-07T23:43:37+00:00 July 7th, 2017|0 Comments

CFPB finalizes amendments to mortgage disclosure rule

Today, the CFPB officially released the finalized updates to its “Know Before You Owe” mortgage disclosure rule, also known as the TILA-RESPA Integrated Disclosure Rule (TRID). According to the Bureau’s press release, the new amendments are intended to “formalize guidance in the rule, and provide greater clarity and certainty.” TRID first took effect in [...]

By | 2017-07-07T21:39:41+00:00 July 7th, 2017|0 Comments

What a recent DC Circuit decision could mean for final CFPB arbitration and payday rules

There have been recent rumors that the CFPB will issue its final arbitration rule by the end of July. According to Ballard Spahr attorney Alan Kaplinsky, “that rumor appears to be gaining traction, with major industry trade group telling its members today that it expects the CFPB to issue a final arbitration rule ‘very [...]

By | 2017-07-07T19:35:55+00:00 July 7th, 2017|0 Comments

Prospect Mortgage hit with $4 million fine for mortgage lending violations

On July 3, 2017, the Department of Justice (DOJ) announced that Prospect Mortgage will pay approximately $4,157,000 to settle allegations the company committed civil mortgage fraud by underwriting mortgages that did not comply with Federal Housing Administration (FHA) standards. According to the DOJ, the California-based mortgage lender engaged in fraud carried out against the Direct [...]

By | 2017-07-07T22:09:15+00:00 July 5th, 2017|0 Comments