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CFPB Spring “Supervisory Highlights”
The Consumer Financial Protection Bureau (CFPB) published two editions of its Spring 2024 Supervisory Highlights. These reports address key findings from recent examinations that highlight violations by furnishers of information to credit reporting agencies and the imposition of illegal junk fees by mortgage servicers. This article focuses on the CFPB’s summary of examinations in connection with furnishers and mortgage servicers.
CFPB’s Circular on AI-based Credit Denials Published
QUESTION: When using artificial intelligence or complex credit models, may creditors rely on the checklist of reasons provided in CFPB sample forms for adverse notices even when those sample reasons do not accurately or specifically identify the reasons for the adverse action?
FinCEN Issues Analysis on Elder Financial Exploitation
On April 18, 2024, FinCEN issued a Financial Trend Analysis report that focuses on patterns and trends identified in Bank Secrecy Act (BSA) data linked to Elder Financial Exploitation (EFE).
TCPA Push Notifications Q&A
QUESTION: Does the federal Telephone Consumer Protection Act (TCPA) apply to push notifications on mobile phones?
Proposed Legislation Would Expand California’s FDCPA to Cover Small Business Debt
California Senate Bill (SB) 1286 has been introduced to expand the scope of the Rosenthal Fair Debt Collection Practices Act (RFDCPA). Currently, the RFDCPA prohibits debt collectors from engaging in unfair or deceptive acts or practices in the collection of consumer debts.
Senate Introduces Proposed Resolution to Overturn SEC’s Climate Disclosure Law
As reported by BCG in April 2024, the Securities and Exchange Commission (SEC) issued a final rule that requires publicly traded companies to include certain climate-related disclosures in their SEC filings, such as registration statements and periodic reports (Climate Disclosure FR).
Agencies Appeal Court’s Grant of Motion for Preliminary Injunction in CRA Lawsuit
As reported last month, the Plaintiffs in the Tex. Bankers Ass’n, et al. v. OCC, et al. lawsuit, which seeks to invalidate the CRA Final Rule, prevailed in their motion for a preliminary injunction to enjoin enforcement of the CRA Final Rule.
Table of Contents
CONSUMER FINANCE
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CFPB Spring “Supervisory Highlights”
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Texas Court Ordered to Rule on CFPB Credit Card Late Fee Final Rule by May 10th
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FHFA Issues New Fair Housing and Fair Lending Rules and Policies
CONSUMER FINANCE Q&A
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CFPB’s Circular on AI-based Credit Denials Published
BANKING OPERATIONS & FINTECH
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FinCEN Issues Analysis on Elder Financial Exploitation
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California Privacy Protection Agency Publishes CCPA Enforcement Advisory
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CISA Proposes New Breach Notification Rules Applicable to Critical Infrastructure
BANKING OPERATIONS & FINTECH Q&A
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TCPA Push Notifications Q&A
COMMERCIAL LENDING
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Proposed Legislation Would Expand California’s FDCPA to Cover Small Business Debt
CORPORATE GOVERNANCE
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Senate Introduces Proposed Resolution to Overturn SEC’s Climate Disclosure Law
CRA/HMDA CORNER
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Agencies Appeal Court’s Grant of Motion for Preliminary Injunction in CRA Lawsuit
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