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IMPORTANT BCG SEMINAR ANNOUNCEMENT
On March 11, 2020 we emailed a statement to our clients (and posted the statement on the BCG website) regarding our firm’s efforts to help contain the spread of the coronavirus. At that time we had determined that we would not cancel any BCG Seminars scheduled for March.
CFPB Proposes Supplemental Rule on Time-barred Debt
On March 3, 2020, the CFPB proposed supplemental changes to its previous proposed revisions to Regulation F which implements the Fair Debt Collection Practices Act. The March 2020 proposal would require specific new notifications regarding time-barred debts that would appear, if applicable, in a debt validation notice or certain other communications. The comment period on the supplemental proposal ends on May 4, 2020.
Conditioning Credit on a Credit Report
Question: May a creditor condition an extension of credit on an applicant having a credit report?
Class Action Compliant Cites CCPA
The California Consumer Privacy Act (CCPA) recently went into effect on January 1, 2020. Although the Attorney General (AG) may not begin enforcing the CCPA until the final regulations are issued, the statutory provisions are now operative. On February 3, 2020, a little over a month after the CCPA took effect, a class action complaint was filed in federal court which cites directly to the CCPA.
DBO Soliciting Comments on Proposed Public Bank Rulemaking
Last year, the California Legislature passed and Governor Newsom signed AB 857 which establishes a process for a local agency to apply for a public bank charter from the DBO. To be a public bank, the local agency must obtain a certificate of authorization to transact business as a bank from the DBO and obtain FDIC insurance.
SB 1235 Disclosure Regulations Still in Works; Questions Purchasers Should Consider
In 2018, the California legislature passed SB 1235, which requires a commercial financing “provider” to provide TILA-like disclosures (for example, a finance charge and APR disclosure) to a “recipient” in connection with an extension or offer of “commercial financing” in an amount of $500,000 or less.
FDIC and OCC Extend Comment Period for Proposed CRA Rules
Last month the FDIC and OCC extended the public comment period for proposed changes to the Community Reinvestment Act (CRA) Rules. In December 2019, the two regulators (without the FRB) announced a plan to modernize the CRA regulations for the first time in 25 years. 85 FR 1204.
Table of Contents
Consumer Finance
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CFPB Proposes Supplemental Rule on Time-barred Debt
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DOD Amends MLA FAQs on GAP Financing; Adds New Q&A on ITIN MLA Scrubs
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“Member FDIC” to Go High-Tech
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GSEs Release Interactive URLA and Omit Language Preference Question
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IRS: Taxpayer First Act Only Applies to Post-December 28, 2019 Transcripts
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U.S. Supreme Court Resolves FDCPA Statute of Limitations Circuit Split
Consumer Finance Q&A
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Conditioning Credit on a Credit Report
Banking Operations & FinTech
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Class Action Complaint Cites CCPA
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CCPA Regulations Expected to be Effective on July 1, 2020
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FDIC FDiTech Releases New Guide to Help FinTechs Connect with Banks
Corporate Governance
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DBO Soliciting Comments on Proposed Public Bank Rulemaking
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What Happens if Your Chief Operating Officer Contracts the Coronavirus?
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House Passes Insider Trading Bill
Commercial Lending
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SB 1235 Disclosure Regulations Still in Works; Questions Purchasers Should Consider
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CFPB Ordered to Issue Final Small Business HMDA Rule
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FRB Publishes SOFR Averages and SOFR Index
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Fannie and Freddie to Discontinue Purchasing LIBOR-based ARMs; Updated ARM Notes and Riders
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SBA Issues Interim Final Rule; Raises CCPA Concerns
CRA/HMDA Corner
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FDIC and OCC Extend Comment Period for Proposed CRA Rules
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