On January 10, 2025, the CFPB announced that it is seeking public input on strengthening privacy protections and preventing harmful surveillance in digital payments, particularly those offered through large technology platforms. In addition, the Bureau requested comment on a proposed interpretive rule outlining how the Electronic Fund Transfer Act (EFTA) applies to new types of digital payment mechanisms.

Jan 8
Jan 8 CFPB Sues Experian for Fake Investigations of Credit Report Errors

Adam Witmer

Regulatory Update

On January 7, 2025, the CFPB sued Experian, the nationwide consumer reporting agency, for unlawfully failing to investigate consumer disputes properly. The CFPB alleges that Experian does not take sufficient steps to intake, process, investigate, and notify consumers about consumer disputes, resulting in the inclusion of incorrect information on credit reports.

Jan 8
Jan 8 CFPB Issues Final Rule to Remove Medical Bills from Credit Reports

Adam Witmer

Regulatory Update

On January 7, 2025, the CFPB finalized a rule that bans the inclusion of medical bills on credit reports used by lenders and prohibits lenders from using medical information in their lending decisions. According to the CFPB, the final rule will remove an estimated $49 billion in medical bills from the credit reports of about 15 million Americans.

Jan 7
Jan 7 CFPB Sues Vanderbilt Over Predatory Manufactured Home Loans

Adam Witmer

Regulatory Update

On January 6, 2025, the CFPB sued Vanderbilt Mortgage & Finance for setting families up to fail when they borrowed money to buy a manufactured home. The CFPB alleges that Vanderbilt’s business model ignored clear and obvious red flags that the borrowers could not afford the loans resulting in many families struggling to make payments.

Jan 6
Jan 6 HMDA Filing Now Open

Adam Witmer

Regulatory Update

On January 1, 2025, the CFPB opened the filing period for HMDA data collected in 2024.Submissions will be considered timely if received on or before March 3, 2025.

Jan 6
Jan 6 NCUA Issues Succession Planning Final Rule

Adam Witmer

Regulatory Update

On December 17, 2024, the NCUA approved a final rule that will require federally insured credit union boards of directors to establish succession planning processes for key positions.

Jan 2
Jan 2 Escrow Exemption Threshold for 2025

Adam Witmer

Regulatory Update, Regulation Z

On December 23, 2024, the CFPB announced the annual adjustment to the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan under Regulation Z. These changes reflect updates to the exemption from TILA’s escrow requirement of creditors that, together with affiliates that regularly extended covered transactions secured by first liens, had total assets of less than $2 billion (adjusted annually for inflation) and the exemption the Bureau added, by implementing section 108 of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), for certain insured depository institutions and insured credit unions with assets of $10 billion or less (adjusted annually for inflation).

Dec 31
Dec 31 OCC Issues Cease and Desist Order Against Bank of America for BSA Deficiencies

Adam Witmer

Regulatory Update, BSA

On December 23, 2024, the OCC issued a cease-and-desist order against Bank of America, N.A. for deficiencies related to its Bank Secrecy Act and sanctions compliance programs. The order requires the bank to take comprehensive corrective actions to enhance its BSA/AML and sanctions compliance programs.

Dec 31
Dec 31 CFPB Takes Action to Stop Illegal Kickback Scheme to Steer Borrowers to Rocket Mortgage

Adam Witmer

Regulatory Update, RESPA

On December 23, 2024, the CFPB sued Rocked Homes to stop them from providing incentives to real estate brokers and agents in exchange for steering homebuyers to Rocket Mortgage, LLC for loans. The CFPB also sued Jason Mitchell, his real estate brokerage firm, JMG Holding Partners LLC, and several real estate brokerage companies for their role in the unlawful scheme.

Dec 30
Dec 30 CFPB Sues Three of the Largest Banks and Zelle for Failure to Protect Consumers from Fraud

Adam Witmer

Regulatory Update

On December 20, 2024, the CFPB sued the operator of Zelle and three of the nation’s largest banks, Bank of America, JPMorgan Chase, and Wells Fargo, for failing to protect consumers from widespread fraud on America’s most widely available peer-to-peer payment network. According to the CFPB, Early Warning Services, which operates Zelle, along with its owner banks rushed the network to market to compete against growing payment apps such as Venmo and CashApp, without implementing effective consumer safeguards.

Jan 13
Jan 13 CFPB Requests Input on Digital Payment Privacy and Consumer Protections

Jan 8
Jan 8 CFPB Sues Experian for Fake Investigations of Credit Report Errors

Jan 8
Jan 8 CFPB Issues Final Rule to Remove Medical Bills from Credit Reports

Jan 7
Jan 7 CFPB Sues Vanderbilt Over Predatory Manufactured Home Loans

Jan 6
Jan 6 HMDA Filing Now Open

Jan 6
Jan 6 NCUA Issues Succession Planning Final Rule

Jan 2
Jan 2 Escrow Exemption Threshold for 2025

Dec 31
Dec 31 OCC Issues Cease and Desist Order Against Bank of America for BSA Deficiencies

Dec 31
Dec 31 CFPB Takes Action to Stop Illegal Kickback Scheme to Steer Borrowers to Rocket Mortgage

Dec 30
Dec 30 CFPB Sues Three of the Largest Banks and Zelle for Failure to Protect Consumers from Fraud

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