Here. Here is the key finding section of the report: The Federal Reserve has set an embarrassingly low bar for issuer disclosures, as evidenced by the 7.5% score its model disclosure received in this study. The Consumer Financial Protection Bureau obviously recognized the inherent flaws with the Federal Reserve’s implemented guidelines for credit card disclosures […]
Category Archives: Consumer Financial Protection Bureau
Here. Behind a paywall, unfortunately. But here's a quote: In more than 2,000 letters responding to the CFPB's plan,bankers said several requirements — including a rigorous timeline for presenting borrowers with the new forms, limited deviation of estimated charges between initial and final disclosures, and an "all-in" annual percentage rate — will add constraints and […]
Creola Johnson of Ohio State has written Congress Protected the Troops: Can the New CFPB Protect Civilians from Payday Lending? 69 Washington & Lee Law Review 649 (2012). Here's the abstract: In 2007, Congress enacted a law, commonly referred to as the Military Lending Act (MLA), which placed a 36% interest rate cap on several […]
by Jeff Sovern Here. It's the usual right-wing attack, most of which has been said before. I refuted some of what he says in August of 2011 in a column in the Pittsburgh Post-Gazette. One other point: Will complains that the Bureau will write law through case-by-case enforcement and that this creates uncertainty. Apparently Will […]
Next Wednesday (November 21), at noon, I'll be presenting a free webinar focusing on the Consumer Financial Protection Bureau's amicus program from both consumer and industry perspectives. On the industry side, I'll be joined by Alan Kaplinsky and Christopher Willis of Ballard Spahr's Consumer Financial Services Group. We'll discuss the factors likely to influence the […]
Creola Johnson of Ohio State has written America's First Consumer Financial Watchdog Is on a Leash: Can the CFPB Use Its Authority to Declare Payday-Loan Practices Unfair, Abusive, and Deceptive? 61 Catholic University Law Review (2012). Here's the abstract: To stop payday lenders from skirting state laws, this Article asserts that the CFPB should exercise […]
by Jeff Sovern One of the big changes in the CFPB's proposed mortgage disclosure forms is the de-emphasis of the APR. The APR has historically been one of the most central Truth in Lending disclosures. For example, for closed-end loans, it must be clear and conspicuous and appear in the "Federal Box" under 12 C.F.R. […]
The American Banker has the story here and here is the Chicago Tribune's coverage. The bill would require the CFPB, as well as other independent federal agencies, to jump through additional hoops before adopting regulations. Many consumer groups have also opposed the bill in a letter.
Here. An excerpt: Lawyers believe Cordray will remain at the helm of the agency until his appointment expires in December 2013, though some predict he'll step down a few months early to run for governor of Ohio. As a result, the CFPB — at least initially — is likely to hold course. That means more […]