A&B ABstract: The CFPB’s Bulletin 2021-01 released on March 31, 2021 announced changes to the Bureau’s type of communications. Does this bulletin suggest a desire of the CFPB to use the examination process for purposes that go beyond the Dodd-Frank Act? The Dodd Frank Act The Dodd-Frank Act grants the CFPB authority to require […]
About Brian Johnson
The CFPB is Sending Mixed Messages on COVID-19 Flexibility
A&B ABstract: The CFPB’s inconsistent statements about the need for flexibility to address the pandemic suggest a deeper game afoot. CFPB warns that continued COVID flexibility for financial institutions is not prudent… On March 31, 2021, the CFPB announced it would be rescinding seven policy statements issued last year that provided financial institutions with flexibilities […]
Payday Lending: A Juxtaposition of Recent CFPB Actions
A&B ABstract: Three recent actions by the Consumer Financial Protection Bureau (“CFPB”), on consecutive days, highlights inconsistencies in the CFPB’s current approach to payday lending. Motion to Dismiss NALCAB Lawsuit On Monday, March 22, 2021, the CFPB filed in D.C. federal district court a memorandum in support of its motion to dismiss a lawsuit filed […]
CFPB Issues Statement Encouraging Financial Institutions and Debt Collectors to Allow Stimulus Payments to Reach Consumers; Creates Potential Consumer Confusion
A&B ABstract: Without additional guidance, the recent statement from the Consumer Financial Protection Bureau (CFPB) about stimulus funds may create consumer confusion. CFPB Raises Concern About EIP Funds Reaching Consumers On March 17, 2021, Acting CFPB Director Dave Uejio issued a statement regarding consumers’ access to Economic Impact Payment (EIP) funds distributed through the American […]
Evaluating the CFPB’s Proposed Delay of the QM Rule: Timing Considerations
A&B ABstract: The CFPB must finalize its proposed QM delay rule in April, likely leaving no room for delay. Background on ATR/QM and the Delay Rule On March 3, 2021, the Bureau of Consumer Financial Protection (CFPB) released a notice of proposed rulemaking (NPRM) to delay the mandatory compliance date of the General Qualified Mortgage […]