May 26, 2016
Unruly Arbitration
I had blogged earlier about the Consumer Financial Protection Bureau’s proposed rule regarding arbitration. Along with 209 other law professors, I submitted a comment letter regarding it. The letter opens, We write to strongly support proposed regulation CFPB-2016-0020, RIN 3170-AA51. … Continue reading
May 26, 2016 in CFPB | Permalink | No Comments
May 11, 2016
Consumer Protection’s Holy Grail
The Federal Financial Institutions Examination Council (FFIEC) has issued a notice and request for comment regarding the Uniform Interagency Consumer Compliance Rating System (the CC Rating System). The FFIEC’s six members represent the Federal Reserve Board, Federal Deposit Insurance Corporation, National Credit … Continue reading
May 11, 2016 in CFPB | Permalink | No Comments
May 6, 2016
Arbitration and the Common Man
Arthur Miller, the playwright who brought us Death of A Salesman, wrote an essay titled Tragedy and The Common Man. It opens, In this age few tragedies are written. It has often been held that the lack is due to … Continue reading
May 6, 2016 in CFPB | Permalink | No Comments
April 25, 2016
TRID Trials
The Consumer Financial Protection Bureau issued the TILA-RESPA Integrated Disclosure (TRID) Rule which went into effect more than six months ago. The TRID Rule were designed to enhance consumer protections in the mortgage application process. The mortgage industry has been … Continue reading
April 25, 2016 in CFPB | Permalink | No Comments
April 22, 2016
Nonbank Mortgage Servicers and the Foreclosure Crisis
The United States Government Accountability Office has issued a report, Nonbank Mortgage Servicers: Existing Regulatory Oversight Could Be Strengthened. The GAO found that The share of home mortgages serviced by nonbanks increased from approximately 6.8 percent in 2012 to approximately 24.2 … Continue reading
April 22, 2016 in CFPB | Permalink | No Comments
April 21, 2016
Couples Leave Money on Closing Table
Geng Li, Weifeng Wu and Vincent Yao, three Fed economists, have posted a research note, Do People Leave Money on the Table? Evidence from Joint Mortgage Applications and the Minimum FICO Rule. The authors state that there “is mounting evidence … Continue reading
April 21, 2016 in CFPB | Permalink | No Comments
April 15, 2016
Consumer Survey Surveillance
As I had noted previously, The Consumer Financial Protection Bureau had issued a notice and request for comment on the Financial Well-Being National Survey. My submitted comments on it are below: The Consumer Financial Protection Bureau has solicited comment on whether this … Continue reading
April 15, 2016 in CFPB | Permalink | No Comments