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Brian Johnson

An Ominous Development in CFPB Supervision

April 27, 2021 By Brian Johnson

  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 […]

Filed Under: Consumer Financial Protection Bureau (CFPB) Tagged With: #MRAs, #supervisoryguidance

The CFPB is Sending Mixed Messages on COVID-19 Flexibility

April 19, 2021 By Brian Johnson

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 […]

Filed Under: Consumer Financial Protection Bureau (CFPB), COVID-19, Mortgage Loans, Mortgage Servicing, Real Estate Settlement Procedures Act (RESPA) Tagged With: #CFPA, #RegulationX

Payday Lending: A Juxtaposition of Recent CFPB Actions

March 30, 2021 By Brian Johnson

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 […]

Filed Under: Consumer Financial Protection Bureau (CFPB) Tagged With: #payday

CFPB Issues Statement Encouraging Financial Institutions and Debt Collectors to Allow Stimulus Payments to Reach Consumers; Creates Potential Consumer Confusion

March 29, 2021 By Brian Johnson

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 […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Debt Collection Tagged With: #EIP

Evaluating the CFPB’s Proposed Delay of the QM Rule: Timing Considerations

March 28, 2021 By Brian Johnson

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 […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Mortgage Loans Tagged With: #QMrule, ATR/QM

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