A&B ABstract: Arizona launched a first-in-the-nation FinTech Sandbox in August 2018, which has been a successful venture by the state. Arizona seeks to improve this program with the enactment of HB 2177 and the Arizona Attorney General Office’s involvement in the CFPB’s American Consumer Financial Innovation Network. Arizona’s FinTech Sandbox In August 2018, Arizona was […]
Consumer Financial Protection Bureau (CFPB)
CFPB Changes Tack on For-Cause Removal Provision
A&B ABstract: In a reversal of its previous position on the issue, the CFPB publicly asserted last month in two separate venues that the for-cause removal provision of the Consumer Financial Protection Act is unconstitutional. On September 17, 2019, CFPB Director Kathleen Kraninger sent two letters (the “Letters”) to Speaker of the House Nancy Pelosi […]
CFPB Rules Permit Qualified Mortgage “Cures”
A&B Abstract: What happens when a proposed qualified mortgage is later discovered to have points and fees in excess of the statutory threshold? The answer lies in a cure provision scheduled to sunset on January 21, 2021. CFPB Rules Permit Qualified Mortgage “Cures” What happens to an originator or assignee of a “qualified mortgage” who […]
CFPB Issues New Edition of Supervisory Highlights
A&B Abstract: The Summer 2019 edition of the CFPB’s Supervisory Highlights indicates recent examination focuses for several categories of consumer credit products. CFPB Issues New Edition of Supervisory Highlights On September 19, the Consumer Financial Protection Bureau (“CFPB”) issued the Summer 2019 edition of Supervisory Highlights, detailing examination findings relating to automobile loan origination, […]
A Closer Look at the CFPB’s Proposed Debt Collection Rules – Part Five: The Devil is in the Details, Purgatory is what is Left Unsaid
A&B Abstract This blog post is part five of a five-part series examining the Consumer Financial Protection Bureau’s (the “CFPB” or “Bureau”) proposed rule amending Regulation F (the “Proposed Rule”), which implements the Fair Debt Collection Practices Act (“FDCPA”) to prescribe rules governing the activities of debt collectors. The idiom “the devil is in the […]