Bank Notes

  • June 8, 2017
    On Thursday, June 8, 2017, CBA and ABA submitted a comment letter in response to the Department of Education’s (DOE) “Request for Information Regarding Disclosures for Student Financial Accounts.” In May the DOE issued the RFI requesting comment on using a model disclosure very similar to that of the recently enacted model short-form disclosure for prepaid cards. In our comment, we strongly...
  • June 8, 2017
    On Thursday, June 8, 2017, the CFPB announced it had sent letters to top retail credit card companies encouraging the use of more transparent transactions. The letter addresses the agency’s concerns with retailers using deferred-interest promotions for credit cards. “With its back-end pricing, deferred interest can make the potential costs to consumers more confusing and less transparent,” said...
  • June 8, 2017
    On Thursday, June 8, 2017, the CFPB held its June meeting of the Consumer Advisory Board, focusing on the Bureau’s recent work with credit invisibles research, deferred interest products, and small business lending. Additonally, (discussed throughout this week’s CBA briefing) CFPB Director Richard Cordray announced the agency planned to promulgate new rules regarding debt collection practices,...
  • June 8, 2017
    On Thursday, June 8, 2017, CBA and the Financial Services Roundtable submitted a joint comment letter in response the CFPB’s request for information on the state of the consumer credit market. The CFPB is required under the Credit Card Accountability Responsibility and Disclosure Act (CARD Act) of 2009 to conduct a review of this market on a biennial basis. In our letter, the Associations...
  • June 8, 2017
    On Thursday, June 8, 2017, the U.S. House of Representatives passed House Financial Services Committee Chairman Jeb Hensarling’s (R-TX) alternative to Dodd-Frank, the Financial CHOICE Act, H.R. 10. The bill passed by a partisan vote of 233 to 186. With a structured rule in place, only six amendments were considered, keeping the bill substantially similar to the version that passed the House...
  • June 7, 2017
    On Wednesday, June 7, 2017, the FDIC announced it would adoptthe Supervisory Guidance on Model Risk Management previously issued by the Board of Governors of the Federal Reserve System (FRB) (SR 11-7) and the OCC (OCC Bulletin 2011-12), with technical conforming changes, thereby making the guidance applicable to certain FDIC-supervised institutions. The guidance addresses supervisory expectations...
  • June 7, 2017
    On Wednesday, June 7, 2017, the CFPB released a study on the transition to credit visibility, anf the varied way in which consumers establish credit history based on economic background. The CFPB reports consumers in lower-income areas are more likely than those in higher-income areas to become credit visible due to negative records, where consumers in higher-income areas are more likely to...
  • June 7, 2017
    On Wednesday, June 7, 2017, the CFPB took action against mortgage servicer Fay Servicing for failing to provide mortgage borrowers with the protections against foreclosure required by law. The Bureau found Fay violated the Bureau’s servicing rules by keeping borrowers in the dark about critical information regarding the process of applying for foreclosure relief. The Bureau also found instances...
  • June 7, 2017
    On Wednesday, June 7, 2017, the OCC issued frequently asked questions (FAQ) to supplement their Bulletin on “Third-Party Relationships: Risk Management Guidance” originally issued October 30, 2013. The FAQ include responses to questions such as what constitutes a third-party relationship, how banks can structure their third-party risk management process, and what collaboration opportunities exist...
  • May 31, 2017
    On Wednesday, May 31, 2017, the CFPB released its monthly complaint report highlighting complaints submitted by older consumers. The snapshot shows older consumers frequently report servicing problems with reverse mortgages, difficulties recovering money after financial scams, confusion around deferred interest credit cards, and charges for unauthorized add-on products. The snapshot provides an...

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