CFPB At It Again


Late last week, IBAT received a number of calls from irate community bankers relative to notice by their core processor of bulk overdraft data request by the CFPB. Although no specific information of any financial institution's data was requested, the collection and remittance of the data will require thousands of man hours by the processors, the cost of which will be passed along to bank customers.

New Proposed Rule


Last week, the CFPB issued a proposed rule to expand HMDA data reporting requirements. In addition to new data points specifically required by the Dodd-Frank Act, the proposal would require collection and reporting of several new data points and the inclusion of some loans not presently covered. Generally the proposal would increase the number of closed-end loans or reverse mortgages made in a year to trigger HMDA reporting from one to 25 in a year.

Updated Compliance Guides


On January 6, 2014, the CFPB updated the TILA Higher-Priced Mortgage Loans (HPML) Escrow Rule - Small Entity Compliance Guide.  This is what the CFPB had to say on the recent update:

"The Bureau updated this guide on January 6, 2014 to reflect finalized changes to the rule. The revisions amend the final rule issued January 10, 2013, which took effect on June 1, 2013. Notable changes in the October 2013 Final Rule, which take effect January 1, 2014, impacting guide content include:



On its website last week, the CFPB called the Ability-to-Repay and Qualified Mortgage rule (ATR/QM rule) "a 'back-to-basics' approach to mortgage lending that will protect consumers from the debt trap of a mortgage they can't afford" and added that it is "a common-sense approach policy that responsible lenders have already been following for decades."  This comment seems to presume that the ATR/QM rule provides the exclusive method for responsible mortgage lending.

New CFPB Bulletin


The CFPB published CFPB Bulletin 2013-10 reminding employers that they cannot require their employees to receive wages on payroll cards. The bulletin also explains some of the federal consumer protections that apply to payroll cards, such as fee disclosure, access to account history, limited liability for unauthorized use, and error resolution rights. Under Reg. E, an employer can require employees to receive their wages electronically, but the employer can't dictate the financial institution used by the employee.


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