A&B ABstract: The Fall 2019 edition of the CFPB’s Supervisory Highlights focuses on credit reporting issues of interest. Discussion The Fall 2019 edition of Supervisory Highlights represents the second time the Consumer Financial Protection Bureau (“CFPB”) has focused entirely on credit reporting. With respect to furnishers, the Supervisory Highlights includes five categories of supervisory observations […]
Consumer Financial Protection Bureau (CFPB)
CFPB Issues Its Fall 2019 Rulemaking Agenda
A&B Abstract: On November 20, 2019, the Consumer Financial Protection Bureau (the “Bureau” or “CFPB”) published its Fall 2019 Rulemaking Agenda (the “Rulemaking Agenda”) as part of the Fall 2019 Unified Agenda of Federal Regulatory and Deregulatory Actions. The Rulemaking Agenda sets forth the matters that the Bureau reasonably anticipates having under consideration during the […]
CFPB Updates Financial Institution Guidance on Elder Financial Exploitation
A&B ABstract: In July 2019, the Consumer Financial Protection Bureau (“CFPB”) issued an update to its 2016 Advisory and Recommendations for Financial Institutions on Preventing and Responding to Elder Financial Exploitation (“Update”). The Update focuses on recent developments in state laws related to elder financial exploitation (“EFE”) and makes a number of recommendations to financial […]
Supreme Court to Decide CFPB’s Constitutionality
A&B ABstract: On October 18, 2019, the Supreme Court granted certiorari in Seila Law v. CFPB to decide the constitutionality of the Consumer Financial Protection Bureau’s leadership structure.[1] Significantly, the Court also ordered the parties to brief and argue a second question: “If the Consumer Financial Protection Bureau [“CFPB”] is found unconstitutional on the basis […]
CFPB Issues Final HMDA Rule Incorporating Reporting Exemptions
A&B ABstract: In a final rule issued on October 10, 2019, the CFPB amended Regulation C under the Home Mortgage Disclosure Act to incorporate exemptions created by the Economic Growth, Regulatory Relief, and Consumer Protection Act, among other changes. Discussion: Effective January 1, 2020, the Consumer Financial Protection Bureau issued a final rule under the […]