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Regulators, industry dig into regulatory relief for community banks (Part 1)
Posted Date: Friday, February 20, 2015
The Senate Banking Committee held two hearings on regulatory relief for community banks and credit unions. The first hearing included testimony from the regulators, while members within the industry testified during the second session. Part 1 of our report focuses on what the regulators discussed.
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Regulators, industry dig into regulatory relief for community banks (Part 2)
Posted Date: Tuesday, February 24, 2015
The Senate Banking Committee held two hearings on regulatory relief for community banks and credit unions. The first hearing included testimony from the regulators while members within the industry testified during the second session. Part 2 of our report focuses on what industry members recommended.
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CFPB offers guidance on confidentiality
Posted Date: Friday, February 6, 2015
In a guidance bulletin issued on Jan. 27, the Consumer Financial Protection Bureau reminded financial institutions what constitutes confidential supervisory information and who can receive it, adding that information contained in non-disclosure agreements do not receive special protection from regulatory reach. The senior vice president of the American Bankers Association’s Center for Regulatory Compliance offered Dodd Frank Update his insight into the guidance. Read on the learn more.
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CFPB proposes expansion of ‘small creditor’ status, ‘rural’ areas
Posted Date: Friday, January 30, 2015
In a move the Independent Community Bankers of America told Dodd Frank Update was “a step in the right direction,” the Consumer Financial Protection Bureau has issued a proposed rule to revise the bureau’s regulatory definitions of “small creditor” and “rural and underserved areas.”
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CFPB acquires supervisory authority over subprime credit company
Posted Date: Friday, February 6, 2015
Under a recent consent order, the Consumer Financial Protection Bureau (CFPB) will supervise and monitor a subprime credit card company that it previously did not have supervisory authority over. How can the CFPB acquire additional supervisory authority? Read on to find out.
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CFPB takes UDAAP action against nonbank lender
Posted Date: Friday, February 13, 2015
The Consumer Financial Protection Bureau took action against a mortgage origination business that engaged in deceptive acts by failing to disclose a payment scheme involving illegal business referrals.
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FHFA proposes nonbank requirements to work with Fannie, Freddie
Posted Date: Tuesday, February 10, 2015
The Federal Housing Finance Agency proposed new minimum financial eligibility requirements for Fannie Mae and Freddie Mac nonbank sellers and servicers that will include net worth, capital ratio and liquidity criteria. Read on to learn more.
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CFPB takes action against ‘deceptive’ advertisements
Posted Date: Tuesday, February 17, 2015
Advertisements cannot mislead consumers into thinking that mortgage lending products are supported, endorsed or affiliated with the U.S. government, according to three enforcement actions taken by the Consumer Financial Protection Bureau. Read on to learn what the three mortgage companies did to allegedly mislead consumers.
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FTC summarizes work in letter to Cordray
Posted Date: Tuesday, February 17, 2015
Under the Dodd-Frank Act, the Consumer Financial Protection Bureau is required to submit annual reports to Congress on the Fair Debt Collection Practices Act. Because the bureau and Federal Trade Commission jointly enforce this Act, the commission sent a lender summarizing its work on debt collection issues. Read on for an overview of the commission’s work.
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Agency enforcement, guidance target private student lending
Posted Date: Tuesday, February 10, 2015
The Consumer Financial Protection Bureau reached a settlement to secure loan forgiveness for borrowers who took out private student loans from Corinthian Colleges. The settlement was announced just days after the bureau and several other federal agencies issued a guidance document on private student loan underwriting.
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Watt defends scorecard, strategy in testimony
Posted Date: Friday, January 30, 2015
The Federal Housing Finance Agency released its 2015 Scorecard to assess the progress Fannie Mae, Freddie Mac and Common Securitization Solutions make in achieving the agency’s goals as outlined in its Strategic Plan for the Conservatorships of Fannie Mae and Freddie Mac. On Jan. 27, FHFA Director Melvin Watt defended several of the agency’s goals and strategies in his testimony before the House Financial Services Committee. Read on to learn more.
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FTC brings first actions against car title lenders
Posted Date: Friday, February 6, 2015
The Federal Trade Commission has entered into proposed settlements against car title lenders, First American Title Lending of Georgia, LLC and Finance Select, Inc., which operated as Fast Cash Title Pawn, for failing to disclose important loan terms through their advertisements. This is the first time the commission has taken action against car title lenders. Read on to learn more about the case and how to submit comments on the proposed consent orders.
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Industry supports OCC promotion of bank collaboration
Posted Date: Tuesday, January 27, 2015
Recognizing the unique challenges community banks face, the Office of the Comptroller of the Currency issued a paper on Jan. 13 that focused on how community banks can do more with less through collaboration. Read on to learn how collaborative arrangements can reduce costs and increase efficiency.
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State UDAAP mortgage scam cases reach settlements
Posted Date: Friday, January 30, 2015
Asserting their authority under Sections 1097 and 1042 of the Dodd-Frank Act, attorneys general from Florida and Connecticut filed a lawsuit against four individuals and their businesses for participating in a mortgage rescue scam. The Florida federal court has approved settlements with several of the defendants. What do these sections of Dodd-Frank say? What were the facts surrounding this case, and what will come from the settlements? Read on to find out.
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Study ties added regulations to declining community bank share
Posted Date: Tuesday, February 17, 2015
In a working paper released from Harvard’s Mossavar-Rahmani Center for Business and Government, it was found that community banks facing added regulatory burdens since the adoption of the Dodd-Frank Act have decreased shares in banking and lending market. Read on to learn more.
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CFPB defines ultimate goal of financial literacy
Posted Date: Friday, February 6, 2015
Under Section 1013(d) of the Dodd-Frank Act, the Consumer Financial Protection Bureau is mandated to develop and implement a strategy to “educate and empower consumers to make better informed financial decisions” and to “improve the financial literacy of consumers.” In a step toward developing a strategy, the bureau studied the concept of financial well-being.
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ABA adds to industry pleas for additional CECL review
Posted Date: Tuesday, February 16, 2016
The American Bankers Association (ABA) has called for the Financial Accounting Standards Board (FASB) to hold additional meetings and issue a new draft standard to address the proposed current expected credit loss model. The FASB held a full-board meeting Feb. 4 in which it met with members of the ABA and Independent Community Bankers of America to discuss how CECL might affect small and community banks.
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Former regulators respond to CFPB’s supervisory approach (Part 2)
Posted Date: Friday, March 27, 2015
At a meeting before The Exchequer Club, Consumer Financial Protection Bureau Deputy Director Steven Antonakes outlined the bureau’s approach to supervision. Part 2 looks at whether the remarks indicate a change in the bureau’s approach, how former regulators interpret the remarks and what covered persons should do in the future.
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Deputy Director pitches CFPB as place to be
Posted Date: Friday, March 27, 2015
Speaking at the Consumer Bankers Association conference in Orlando, Fla., Consumer Financial Protection Bureau Deputy Director Steven Antonakes talked about the bureau’s enforcement pattern, but he also made a pitch to the financial experts in the room. Read on to see what he had to say.
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FTC hands down auto dealer enforcements
Posted Date: Friday, March 27, 2015
As part of a wider operation, the Federal Trade Commission has announced six enforcement actions against auto dealers, primarily involving vehicle purchase add-ons and deceptive advertising. Read on for details of the actions, which include the agency’s first involving add-ons since gaining expanded authority over auto dealers under the Dodd-Frank Act.
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Committee sends 11 regulatory reform bills to House floor
Posted Date: Friday, March 27, 2015
In its markup session last week the House Financial Services Committee pushed 11 bills to the floor of the House. All of them previously had passed the committee or full House in the same or slightly different versions last year; none were taken up by the Senate. Read on to see what could be on congressional minds.
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CFPB outlines proposed rule for payday lending
Posted Date: Thursday, March 26, 2015
The Consumer Financial Protection Bureau hosted its field hearing in Richmond, Va., and heard from a variety of consumers and lenders. The bureau has released an outline of its rule, which will aim to promote better underwriting, and prevent cycles of borrowing and excessive fees. Many lenders and borrowers weighed in on the issue; read on to hear what they had to say.
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Dodd Frank Update on site for payday lending hearing Thursday
Posted Date: Tuesday, March 24, 2015
Two years after it published a whitepaper on the payday lending industry, the Consumer Financial Protection Bureau hosts a second field hearing on the industry. It is expected to announce proposed rules governing small-dollar credit loans. Read on for a preview and see what the bureau might propose in its rules.
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CFPB asks for input on credit cards
Posted Date: Tuesday, March 24, 2015
Every two years, the Credit Card Accountability, Responsibility, and Disclosure Act requires the Consumer Financial Protection Bureau to review the consumer credit market. The bureau recently launched a public inquiry on the industry. Read on for the details of what it entails.
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Live coverage: Conference turns focus onto consumers
Posted Date: Tuesday, March 24, 2015
The Consumer Bankers Association opened its CBA Live conference Monday. This year’s theme centers on the consumer agenda. How will your customers shape the future of banking?
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RealEC sets agent registration for Closing Insight
Posted Date: Tuesday, March 24, 2015
RealEC Technologies announced a schedule for registration for Closing Insight. Settlement agents can access Closing Insight in two different ways. Read on for the details.
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Court rules on notice-and-comment process for interpretive rules
Posted Date: Friday, March 20, 2015
The U.S. Supreme Court recently handed down a decision on whether a regulatory agency, such as the Consumer Financial Protection Bureau, needs to engage in notice-and-comment rulemaking when significantly altering an interpretive rule. The ruling could have a major impact on regulatory authority going forward. Read on for the results.
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Consumer choice linked to regulatory relief, panelists say
Posted Date: Friday, March 20, 2015
Big Brother, “too brute to prosecute,” football, repealing the Dodd-Frank Act – the House Financial Services Committee addressed a hodgepodge of topics in its hearing titled “Preserving Consumer Choice and Financial Independence.”
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Cordray: Consumers, lend us your stories!
Posted Date: Friday, March 20, 2015
The Consumer Financial Protection Bureau will start accepting narratives from consumers within its Consumer Complaint Database. Director Richard Cordray explained the changes on the CFPB’s blog. Read on to hear what the American Bankers Association President and CEO Frank Keating had to say about it.
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FTC charges DirecTV with deceptive advertising
Posted Date: Friday, March 20, 2015
The Federal Trade Commission’s recent complaint against DirecTV is another example of regulation through enforcement that service providers should be aware of. In this case, the FTC charged DirecTV with deceptive advertising. Read on for details of the case.
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CFPB to consumers: Be wary of pension advance traps
Posted Date: Friday, March 20, 2015
As the Consumer Financial Protection Bureau’s payday loan field hearing approaches, the bureau has issued a warning for consumers on another high-interest cash advance: pension advances. What warnings have the bureau issued? Read on to find out.
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Wells Fargo offers TRID guidance to agents
Posted Date: Tuesday, March 17, 2015
In Wells Fargo’s latest quarterly newsletter to settlement agents who close loans with the lender, Wells announces the technology partner with whom agents will be connecting to, as well as answering more questions regarding the company’s plans for the TILA-RESPA Integrated Disclosure Rule implementation Aug. 1. Read on for the details.
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Two fail second part of Fed stress test
Posted Date: Tuesday, March 17, 2015
In the second part of its stress tests for U.S.-based bank holding companies, the Federal Reserve board did not approve of two capital plans and only provisionally approved one other, despite all 31 companies passing the first part of the stress test. Read on to find out who did not pass, and why.
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Appraisers offer Dodd-Frank recommendations
Posted Date: Tuesday, March 17, 2015
Six appraisal organizations offered policies recommendations under the Dodd-Frank Act’s qualified mortgage lending regulations, among other topics. Read on to learn more.
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FSOC approves minutes on SIFI process
Posted Date: Tuesday, March 17, 2015
The Financial Stability Oversight Council approved the minutes from its January and February meetings. Read on for a brief summary of what was discussed.
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Cordray talks QM, HMDA, TRID
Posted Date: Friday, March 13, 2015
Consumer Financial Protection Bureau Director Richard Cordray appeared before the House Financial Services Committee to discuss the bureau’s 6th semi-annual report and answer questions about mortgage loan disclosures, qualified mortgages and more.
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Congress introduces several bills to reform Dodd-Frank
Posted Date: Tuesday, March 10, 2015
From changing the Consumer Financial Protection Bureau’s leadership from a director to a commission to creating a mechanism for businesses to appeal the bureau’s designation of rural or underserved areas, members of Congress have been very busy. Read on for a roundup of bills to watch down the road.
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Waters raises concerns about unilateral subpoena powers
Posted Date: Tuesday, March 10, 2015
The Consumer Financial Protection Bureau may face subpoenas from House Financial Services Committee Chairman Rep. Jeb Hensarling, R-Texas, but Ranking Member Rep. Maxine Waters, D-Calif., has expressed concerns of possible abuse.
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ICBA gets new chairman
Posted Date: Tuesday, March 10, 2015
The Independent Community Bankers of America welcomed a new chairman. Read on to learn more about his message to community bankers.
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Representative puts SIFI focus on new target
Posted Date: Friday, March 6, 2015
In a recent House Financial Services Committee hearing, one representative suggested that the designation of a systemically important financial institution should be granted to a new class of organizations.
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Agencies work to address SIFI designations
Posted Date: Friday, March 6, 2015
The Financial Stability Oversight Council adopted new practices relating to its Title I review process for designating nonbank financial companies. Additionally, the council and the Federal Reserve Board have extended the comment periods for two proposals regarding asset management products and services and risked-based capital surcharges.
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FTC complaints allege abusive debt collection
Posted Date: Friday, March 6, 2015
The Federal Trade Commission has filed several complaints against debt collectors, including those targeting consumer with outstanding payday loans, for violations under the Fair Debt Collection Practices Act.
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Takeaways from recent Cordray remarks
Posted Date: Friday, March 6, 2015
In addition to appearing before the House Financial Services Committee, Consumer Financial Protection Bureau Director Richard Cordray issued prepared remarks before the National Association of Attorneys General and the Consumer Advisory Board.
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Inspector general refuses to sign off on Ginnie Mae statements
Posted Date: Friday, March 6, 2015
The inspector general for the U.S. Department of Housing and Urban Development stated in a report that it could not sign off on financial statements made by Ginnie Mae because of accounting errors and the agency’s failure to provide enough information.
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Cordray on the Hill, and more, in March
Posted Date: Friday, February 27, 2015
Consumer Financial Protection Bureau Director Richard Cordray will be appearing on the Hill to give the bureau’s semi-annual report to Congress under Section 1016 of the Dodd-Frank Act. Additionally, there will be several other upcoming deadlines and events regarding the bureau, including a job application deadline, an arbitration field hearing and five comment session closings. Read on to find out what is happening in March.
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CFPB proposes suspending credit card submissions
Posted Date: Friday, February 27, 2015
To buy time to streamline its credit card agreement submission process, the Consumer Financial Protection Bureau is proposing to temporarily suspend the requirement that credit card issuers submit their agreements on a quarterly basis. Is the bureau taking a cost-benefit approach to its operations? Read on to find out.
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Groups push for limited-English-proficiency consumer protections
Posted Date: Friday, February 27, 2015
Industry members should anticipate regulations that focus on protecting limited-English-proficiency consumers. Two advocacy groups have asked the Consumer Financial Protection Bureau to protect limited-English-proficiency consumers in its mortgage servicing rules, with one urging the addition of more languages to the new integrated mortgage disclosure forms.
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Yellen says Fed plans no changes to Dodd-Frank
Posted Date: Friday, February 27, 2015
Federal Reserve Board Chairwoman Janet Yellen told Senate and House members last week that the Fed did not plan to alter the Dodd-Frank Act. Read on for the details of why.
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FDIC releases regulatory capital tool for securitization exposures
Posted Date: Friday, February 27, 2015
To help financial institutions calculate their risk-based capital requirements for securitization exposures, the Federal Deposit Insurance Corp. published a simplified supervisory formula approach tool that banks may use under the revised capital rules.
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House reintroduces CFPB inspector general bill
Posted Date: Tuesday, February 24, 2015
A bipartisan bill was introduced in the House that would establish an independent inspector general for the Consumer Financial Protection Bureau.
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Forum looks at costs-benefits of Dodd-Frank
Posted Date: Tuesday, February 24, 2015
According to the American Action Forum, regulatory agencies have failed to calculate 35.8 million burden hours from 51 different Dodd-Frank Act compliance regulations.
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ABA seeks detailed examples of regulatory burdens
Posted Date: Friday, February 20, 2015
During the Senate Banking Committee’s Feb. 12 hearing on regulatory relief for community banks and credit unions, senators asked industry representatives about the specific laws and regulations that prevent community bankers from servicing their customers. The American Bankers Association has launched an online form for bankers to submit their stories to the committee. Read on to learn more and to access the online form.
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Bill may eliminate annual privacy notices
Posted Date: Friday, February 20, 2015
The Privacy Notice Modernization Act has been reintroduced in the Senate. The bill would change the requirement of annual privacy notices under the Gramm-Leach-Bliley Act.
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SEC proposes to amend disclosure requirements
Posted Date: Friday, February 20, 2015
The Securities and Exchange Commission has proposed amendments that will implement Section 955 of the Dodd-Frank Act, which requires the disclosure of hedging by employees and directors. Read on to learn more.
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FDIC announces new Advisory Committee members
Posted Date: Friday, February 20, 2015
The Advisory Committee on Community Banking will get seven new members, according to an announcement from the Federal Deposit Insurance Corp. Read on to find out who will be providing advice and recommendations to the corporation.
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Deputy comptroller addresses cyber threats
Posted Date: Tuesday, February 17, 2015
In a speech at The Clearing House’s Operational Risk Colloquium, the Office of the Comptroller of the Currency’s Deputy Comptroller for Operational Risk Beth Dugan discussed operational risks, cyber threats and the importance of effective risk management. Read on to learn about the recommended strategies to addressing risks.
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FHFA increases community asset cap
Posted Date: Tuesday, February 17, 2015
The cap on average total assets for a “community financial institution” has been raised from $1.108 billion to $1.123 billion. Read on for the details of why it changed.
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Industry weighs in on boarding form
Posted Date: Friday, February 13, 2015
The Consumer Financial Protection Bureau is proposing a boarding form to facilitate company participation with the Consumer Complaint Database. Read on to learn what industry members and trade groups have to say about the proposal.
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Bill would cap CFPB’s 2016 budget
Posted Date: Friday, February 13, 2015
The Unfunded Mandates Information and Transparency Act of 2015 was passed in the House on Feb. 4 and contains a late amendment that would cap the Consumer Financial Protection Bureau’s budget. Read on to learn more about the cap and the purpose of the bill.
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FFIEC revision addresses third-party practices
Posted Date: Friday, February 13, 2015
In a new appendix to its Information Technology Examination Handbook, the Federal Financial Institutions Examination Council offered suggestions for strengthening the resiliency of outsourced technology services.
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Husband, wife ordered to pay for mortgage kickbacks
Posted Date: Friday, February 13, 2015
A husband and wife must pay a civil penalty and report to the Consumer Financial Protection Bureau for their involvement in a mortgage kickback scheme. Read on to learn what else they must do under the bureau’s consent order.
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CFPB looks at reverse mortgage complaints
Posted Date: Friday, February 13, 2015
Section 1013 of the Dodd-Frank Act, authorizes the Consumer Financial Protection Bureau to collect, monitor and respond to consumer complaints. In its latest snapshot of complaints received, the bureau examines issues concerning reverse mortgages.
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Tarullo speaks on macroprudential policy objectives
Posted Date: Tuesday, February 10, 2015
In a speech hosted by the Office of Financial Research and Financial Stability Oversight Council, Federal Reserve Board Governor Daniel Tarullo said the principle that prudential requirements should increase in stringency with the systemic importance of regulated firms is embodied in Section 165(a) of the Dodd-Frank Act. Read on to learn about the three major macroprudential policy objectives Tarullo suggested.
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Budget puts Dodd-Frank spotlight on CFTC
Posted Date: Tuesday, February 10, 2015
The budget President Barack Obama released puts the Dodd-Frank spotlight on the Commodity Futures Trading Commission (CFTC) – and swaps.
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FTC settles second case against prepaid mobile provider
Posted Date: Tuesday, February 10, 2015
The Consumer Financial Protection Bureau is not the only agency bringing enforcement actions against cell phone companies. The Federal Trade Commission secured $40 million from the largest prepaid mobile provider in the U.S. to settle charges that it deceived consumers with false promises of “unlimited” data service. How is this case different from the bureau’s ongoing case against Sprint? Read on to find out.
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S&P settles another case for misleading rates
Posted Date: Friday, February 6, 2015
Just weeks after settling with the Securities and Exchange Commission to pay $77 million for misleading the public on its rating methods, Standard & Poor has reached another settlement on charges that the company inflated ratings on mortgage-backed securities and other assets, an action that officials say helped set off the financial crisis and recession.
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FDIC: Take risk-based approach in assessing customers
Posted Date: Friday, February 6, 2015
In a statement issued on Jan. 28, the Federal Deposit Insurance Corp. encouraged financial institutions to take a risk-based approach in assessing individual customers rather than declining to provide banking services to entire categories of customers.
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ABA: Dodd-Frank, Rate Checker needs changing
Posted Date: Friday, January 30, 2015
From writing op-eds and providing guidance documents to members of Congress to writing direct letters to the Consumer Financial Protection Bureau’s director, the American Bankers Association has been busy this January, addressing policy initiatives and the bureau’s “Owning a Home” interest rate tool. Read on to learn what the trade group has been up to.
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SEC takes first action against major ratings firm
Posted Date: Friday, January 30, 2015
In its “first-ever” enforcement action against a major ratings firm, the Securities and Exchange Commission announced a series of federal securities law violations against Standard & Poor.
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CFTC commissioner: End-users did not cause financial crisis
Posted Date: Friday, January 30, 2015
In a keynote address at the Commodity Markets Council’s State of the Industry Conference, a commissioner from the Commodity Futures Trading Commission stressed the need to make sure Title VII of the Dodd-Frank Act is not burdening “Main Street.”
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Supreme Court clarifies TILA rescission
Posted Date: Tuesday, January 27, 2015
In Jesinoski v. Countrywide Home Loans, Inc., the U.S. Supreme Court clarified the requirements for rescinding a contract under the Truth in Lending Act.
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CFPB fills several leadership positions
Posted Date: Tuesday, January 27, 2015
Know your regulators: On Jan. 23 the Consumer Financial Protection Bureau announced the addition of several new members who will take on leadership roles at the bureau. The positions include assistant director of enforcement, deputy chief operating officer, northeast regional director of supervision examinations, and chief human capital officer.
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House committee to keep eye on CFPB rulemaking, FSOC effectiveness
Posted Date: Tuesday, January 27, 2015
The House Financial Services Committee released its oversight plan for the 114th Congress. The plan contains several initiatives involving the Consumer Financial Protection Bureau, the Financial Stability Oversight Council, and other regulatory bodies and policies under the Dodd-Frank Act.
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CFPB leaves out financial institution in action against Wells, Chase
Posted Date: Friday, January 23, 2015
It’s usually said that “no good deed goes unpunished” but for the Unnamed Financial Institution mentioned in the Consumer Financial Protection Bureau’s complaint against Wells Fargo, JPMorgan Chase and certain loan officers involved in an illegal marketing services scheme, that wasn’t the case. Read on to learn how the financial institution avoided an enforcement action.
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CFPB finalizes disclosure rules
Posted Date: Friday, January 23, 2015
The Consumer Financial Protection Bureau recently finalized two modifications to the “Know Before You Owe” mortgage disclosure rules. Read on to learn more about what has been finalized.
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Agencies release public portions of living wills
Posted Date: Friday, January 23, 2015
Under the Dodd-Frank Act, bank holding companies with total consolidated assets of $50 billion or more and nonbank financial companies designated for enhanced prudential supervision by the Financial Stability Oversight Council are required to submit resolution plans to the Federal Reserve Board and the Federal Deposit Insurance Corp. describing the company’s resolution strategy in the event of material financial distress or failure. The public versions of these resolutions, commonly known as living wills, recently have been released. Read on for the details.
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Dodd-Frank TILA amendments added to OCC booklet
Posted Date: Friday, January 23, 2015
The Office of the Comptroller of the Currency updated its “Truth in Lending Act” booklet in its Comptroller’s Handbook to reflect revisions from the Dodd-Frank Act. The previous booklet had not been updated since December 2010.
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Pew reveals public views of U.S. economy
Posted Date: Friday, January 23, 2015
In his State of the Union address, President Barack Obama pledged to veto any bill that threatens to unravel the Dodd-Frank Act’s rules on Wall Street, stressing that current regulations have helped the economy grow. But how does the public feel about the economy and financial regulation? Read on to find out.
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CFPB cites Wells, Chase, Maryland title firm for illegal kickbacks
Posted Date: Thursday, January 22, 2015
The Consumer Financial Protection Bureau and the Maryland Attorney General announced actions against Wells Fargo and JPMorgan Chase for engaging in illegal marketing services with a now-defunct title company, Genuine Title. In addition to the banks, the bureau and Maryland took action against a former Wells Fargo employee and his wife for their involvement. In all, the penalties for the enforcement total more than $35 million.
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