A&B Abstract The CFPB has issued an Advance Notice of Proposed Rulemaking regarding the fate of the “QM Patch,” indicating that it will not extend the “QM Patch” permanently. Advanced Notice of Proposed Rulemaking In a surprise development, on July 25, 2019, the Consumer Financial Protection Bureau (“CFPB”) issued an advance notice of proposed rulemaking […]
Consumer Financial Protection Bureau (CFPB)
A Closer Look at the CFPB’s Proposed Debt Collection Rules – Part One
A&B Abstract: On May 7, 2019, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) issued a proposed rule that would significantly amend Regulation F (the “Proposed Rule”), which implements the Fair Debt Collection Practices Act (“FDCPA”), to prescribe rules governing the activities of debt collectors that are subject to the FDCPA. The Bureau recently […]
The Fate of the QM Patch
A&B Abstract: With the January 2021 expiration of the so-called “QM Patch” looming, what courses of action are available to the CFPB? Background One of the most vexing issues currently facing the Consumer Financial Protection Bureau (“CFPB”) is the fate of the so-called “QM Patch”. The CFPB’s ability-to-repay/qualified mortgage regulations promulgated pursuant to the Dodd-Frank […]
Will the CFPB find its Voice on “Abusiveness”?
On June 25, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) kicked off its symposia series with a panel discussion of whether the Bureau should use its rulemaking authority to further define “abusive acts or practices.” The Dodd-Frank Act added a prohibition on abusive acts and practices to the established prohibition on unfair acts and […]
New York DFS Unveils Two New Divisions Focused on Consumer Protection, Financial Enforcement and Cybersecurity
New York State’s Department of Financial Services (DFS) recently unveiled two new divisions with broad enforcement authority focused on consumer protection, financial enforcement, and cybersecurity. Financial service providers should take note as New York and other states continue to shore up their enforcement capabilities. Consumer Protection & Financial Enforcement DFS’ highly touted Consumer Protection and […]