Tag: Consumer Financial Protection Bureau

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US Consumer Financial Protection Bureau Seeking Comments on Proposed Remittance Rule Revisions
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CFPB Seeking Comments On Possible Remittance Rule Revisions
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Marketplace lender seeking fair lending guidance receives CFPB’s first no-action letter
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CFPB Finalizes Much-Anticipated Prepaid Account Rule

US Consumer Financial Protection Bureau Seeking Comments on Proposed Remittance Rule Revisions

Jeremy M. McLaughlin and Daniel S. Cohen

On December 3, the United States Consumer Financial Protection Bureau (“CFPB”) published a notice of proposed rulemaking to revise the Remittance Rule (“Proposed Rule”) and is accepting comments until January 21, 2020.  The proposal follows the CFPB’s April 2019 request for information on the Remittance Rule (see here for our previous discussion).  The key provisions of the Proposed Rule address two aspects of the Remittance Rule: (1) the Rule’s applicability to a company that executes 100 or more remittances per year in the normal course of business, and (2) the Rule’s allowance for insured banks and credit unions to disclose estimates, rather than exact figures, under certain circumstances. This latter allowance is set to expire on July 21, 2020.

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CFPB Seeking Comments On Possible Remittance Rule Revisions

By Daniel S. Cohen and Jeremy M. McLaughlin

On April 25th, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a request for information (“RFI”) asking for input about the scope of its Remittance Rule (the “Rule”), whether the Bureau should exempt certain small financial institutions from the Rule, and how the expiration of the Rule’s “temporary exemption” for insured depository institutions and credit unions would adversely affect consumers.  Comments are due 60 days after publication in the Federal Register.

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Marketplace lender seeking fair lending guidance receives CFPB’s first no-action letter

By David D. Christensen, Jennifer Janeira Nagle and Brandon R. Dillman

The U.S. Consumer Financial Protection Bureau (CFPB) recently issued its first no-action letter, pursuant to a policy designed to encourage innovation in the fintech marketplace by creating a testing ground for new technologies. If received, a no-action letter simply indicates that the CFPB “has no present intention to recommend initiation of an enforcement or supervisory action” against the applicant with respect to the specific product and regulatory concerns at issue.

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CFPB Finalizes Much-Anticipated Prepaid Account Rule

By Eric A. Love, Linda C. Odom and Judith Rinearson

On October 5, the Consumer Financial Protection Bureau (“CFPB”) issued its much-anticipated Final Rule for prepaid accounts under the implementing regulations for the Electronic Fund Transfer Act (Regulation E) and the Truth In Lending Act (Regulation Z).  The Final Rule is effective on October 1, 2017 and governs “prepaid accounts” including:*

  • general purpose reloadable cards
  • mobile wallets and certain other electronic prepaid accounts
  • peer-to-peer payment products
  • student financial aid disbursement cards
  • tax refund cards
  • payroll cards
  • government benefit cards

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