On August 11, 2022, the CFPB issued the above Circular 2022-04 ( herein “Circular”) in which the CFPB answers the question “Can...
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Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.
FDIC Makes Technical Corrections to 12 CFR §338.4(b) and Part 343 Appendix A
In the August 8, 2022, issue of the Federal Register (87 FR 48079) the Federal Deposit Insurance Corporation (FDIC) made...
Regulation Implementing the Adjustable Interest Rate (LIBOR) Act
In the July 28, 2022, issue of the Federal Register (87 FR 45268) the Federal Reserve Board (“Board”) published a proposed...
CFPB Advisory Opinion “Fair Credit Reporting; Permissible Purposes for Furnishing, Using, and Obtaining Consumer Reports”
In the July 12, 2022, issue of the Federal Register (87 FR 41243) the CFPB published the above Advisory Opinion (the “Opinion”)...
Mortgagee Letter 2022-09 Update for COVID-19 Related Economic Event
On July 7, 2022, the Federal Housing Administration (FHA) issued updated Mortgagee Letter 2022-09 (ML 2022-09) that will allow...
Joint Financial Regulatory Agencies Amend Business Day Definition in §153.1(2) of the Home Equity Lending Interpretations.
In the July 8, 2022, Texas Register (47 TexReg 3969), the Finance Commission of Texas and the Texas Credit Union Commission...
Regulation V— Prohibition on Inclusion of Adverse Information in Consumer Reporting in Cases of Human Trafficking
In the June 24, 2022, issue of the Federal Register (87 FR 37700) the Consumer Financial Protection Bureau (Bureau) published a...
Loans in Areas Having Special Flood Hazards; Interagency Flood Insurance
On May 31, 2022, the Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board),...
CFPB Circular 2022-03— Credit Decisions Based on Complex Algorithms
On May 26, 2022, the CFPB issued Circular 2022-03 explaining a creditor’s responsibility to comply with ECOA’s requirement to...
5-23-22 CFPB Issues Interpretive Rule on State Enforcement of Consumer Financial Protection Laws5-23-22 Rev 5-26-22 CFPB Issues Interpretive Rule on State Enforcement
On May 19, 2022, the Consumer Financial Protection Bureau issued an Interpretive Rule providing the following interpretations to...