On February 3, 2020, the CFPB released their semi-annual report for the Fall of 2019. This version of the regular report to Congress covers the period beginning on April 1, 2019 and ending on September 30, 2019.
As is the case in each semi-annual report to Congress, the CFPB includes a number of topics ranging from challenges consumers face to a summary of new rules adopted by the Bureau. While some of this information isn’t extremely important to compliance professionals, the following sections could be important for financial institutions:
List of Significant Rules Adopted by the CFPB
The third section of the report discusses a list of significant rules adopted by the CFPB for the time period covered in the report. The Bureau explained that they issued the following rules:
Significant Rules
Proposed Rule: Payday, Vehicle Title, and Certain High-Cost Installment Loans
Proposed Rule: Debt Collection Practices (Regulation F)
Final Rule: Payday, Vehicle Title, and Certain High-Cost Installment Loans; Delay of Compliance Date; Correcting Amendments. This rule was issued to delay the August 19, 2019 compliance date for the mandatory underwriting provisions of the regulation promulgated by the CFPB in November of 2017. The provisions finalized in 2017 were delayed by 15 months to November 19, 2020 in order to give the Bureau time to re-evaluate the rule.
Less Significant Rules
Final Rule: Technical Specifications for Submission to the Prepaid Account Agreements Database
Final Rule: Availability of Funds and Collection of Checks (Regulation CC)
Final Rule: Home Mortgage Disclosure (Regulation C) - 2019 Final Rule
Proposed Rule: Home Mortgage Disclosure (Regulation C)
Plan for Upcoming Rules
In their annual report, the CFPB also included their plan for upcoming rules. This plan, which basically just reiterated the Bureau’s previously published Fall 2019 Rulemaking Agenda, included the following upcoming initiatives:
Pre-rulemaking initiatives:
Business Lending Data (Regulation B)
Higher-Priced Mortgage Loan Escrow Exemption
Property Assessed Clean Energy (PACE) Financing
Qualified Mortgage Definition Under the Truth in Lending Act
Proposed Rules:
Remittance Transfers
Home Mortgage Disclosure Act (Regulation C) Data Collection and Reporting Requirements
Public Release of Home Mortgage Disclosure Act Data
Final Rules:
Payday, Vehicle Title, and Certain High-Cost Installment Loans
Home Mortgage Disclosure Act (Regulation C)
Plan for Upcoming Initiatives by the CFPB
The CFPB has listed the following as upcoming initiatives:
Symposia Series - 1) On small business lending, 2) consumer access to financial data, 3) cost-benefit analysis, and 4) the disparate impact doctrine under the ECOA.
CFPB-FTC Workshop - on credit reporting accuracy.
Research Reports - on topics like experience of student loan borrowers using income-driven repayment plans; a report on public records, credit reports and credit performance; and a report on small business lending before, during and after the Great Recession; and a report on applications for mortgages.
Research Conference - will be the fourth research conference hosted by the CFPB and will include six sessions where leading researchers will present research papers.
Section 610 Review - to include a review of the 20019 overdraft regulation.
TRID Assessment - to review factors such as whether TRID rules meet the purpose and objectives of the Dodd-Frank Act.
Abusiveness - the Bureau will publish a Policy Statement with respect to the manner in which it will apply the abusiveness provision of the Dodd-Frank Act in its supervisory and enforcement work.
MOU with the Department of Education - to coordinate efforts to oversee regulated entities and protect consumers.
Other initiatives - such as consumer outreach and departmental restructuring and consolidations.
The full report can be found here.
