CFPB’s Fall 2018 Rulemaking Agenda
CFPB’s Fall 2018 Rulemaking Agenda
The CFPB has been busy so far in 2018 and there is no slowing down as the year comes to an end. The following is a listing of items on the CFPB’s Fall 2018 agenda. Is your financial institution aware of the possible upcoming rulemakings?
- Home Mortgage Disclosure Act (HMDA) – In August 2018 a clarification regarding EGRRCPA amendments to HMDA was released. This creates a partial exemption to allow certain insurance depository institutions and insured credit unions not to report certain data points for certain transactions. An additional notice and comment should commence in Spring 2019. The additional notice and comment should incorporate interpretations and procedures into Regulation C.
- Fair Debt Collection Practices Act (FDCPA) – The CFPB expects to issue a Notice of Proposed Rulemaking addressing such issues as communication practices and consumer disclosure by March 2019 due to debt collection being the top source of complaints to the Bureau. This notice would be in relation to the outline of proposals under consideration in July 2016, concerning practices by companies that are debt collectors under FDCPA.
- Payday, Vehicle Title, and Certain High-Cost Installment Loans – The Bureau intends to open a rulemaking to reconsider its 2017 rule titled Payday, Vehicle Title and Certain High-Cost Installment Loans. The rule has a compliance date in August 2019. A Notice of Proposed Rulemaking should be issued no later than early 2019 which will address reconsideration of the rule of the merits as well as address changes to its compliance date.
- Abusive Acts and Practices – The Bureau is considering if rulemaking or other activities may be helpful to further clarify the meaning of abusive acts or practices under Section 1031 of the Dodd-Frank Act.
- Amendments to FIRREA Concerning Appraisals – The FIRREA amendments require implementing regulations for quality control standards for Automated Valuation Models (AVMs) designed too ensure a high level of confidence in the estimates produced by the valuation models, protect against the manipulation of data, seek to avoid conflicts of interest, require random sample testing and reviews, and account for any other such factor the Agencies determine to be appropriate.
- Regulation E Modernization – The Bureau is to evaluate possible updates to the regulation, including but not limited to, how providers of new and innovative products and services comply with regulatory requirements. Other potential topics may include disclosure provisions and error resolution provisions.
- EGRRCPA – The CFPB plans to issue proposals addressing expanded exemptions from mortgage escrow requirements for certain creditors with assets of $10 billion or less.
For additional information contact Natalie Reifsneider at nreifsnider@fosaudit.com.
CFPB’s Fall 2018 Rulemaking Agenda | Natalie Reifsneider