CFPB Releases Report on Medical Debts

Adam Witmer
Regulatory Update

On March 1, 2022 the CFPB issued a report highlighting the complicated and burdensome nature of the medical billing system in the United States. The report reveals that the U.S. healthcare system is supported by a billing, payments, collections, and credit reporting infrastructure where mistakes are common, and where patients often have difficulty getting these errors corrected or resolved.

CFPB Moves to Mitigate Illegal Automobile Repossessions

Adam Witmer
Regulatory Update, UDAAP

On February 28, 2022, the CFPB issued a compliance bulletin regarding repossession of vehicles, and the potential for violations of the Dodd-Frank Act’s prohibition on engaging in unfair, deceptive, or abusive acts or practices when repossessing vehicles. This is after the CFPB observed, during its examinations and enforcement actions, illegal seizure of cars, sloppy record keeping, unreliable balance statements, and ransom for personal property.

CFPB Outlines Options to Prevent Algorithmic Bias in Home Valuations

Adam Witmer
Regulatory Update, Fair Lending

On 2/23/2022, the CFPB outlined options to ensure that computer models used to help determine home valuations are accurate and fair. The options will now be reviewed to determine their potential impact on small businesses. According to the CFPB’s release, automated valuation models can pose fair lending risks to homebuyers and homeowners. The CFPB is particularly concerned that without proper safeguards, flawed versions of these models could digitally redline certain neighborhoods and further embed and perpetuate historical lending, wealth, and home value disparities.

OCC Issues FAQs on the December 2021 CRA Final Rule

Adam Witmer
Regulatory Update, CRA

On 2/22/2022, the OCC issued answers to frequently asked questions (FAQ) about the December 2021 final rule to rescind the OCC's Community Reinvestment Act (CRA) rule issued on June 5, 2020 (June 2020 CRA rule). The December 2021 CRA final rule, which became effective on January 1, 2022, replaced the June 2020 CRA rule with provisions largely based on the rules adopted jointly by the OCC, the FRB, and the FDIC in 1995, as revised.

Interagency Statement on Special Purpose Credit Programs Under the ECOA and Reg B

Adam Witmer
Regulatory Update, Regulation B, Fair Lending

On 2/22/2022, the FRB, FDIC, NCUA, OCC, CFPB, HUD, the DOJ, and the FHFA issued an interagency statement to remind creditors of the ability under the Equal Credit Opportunity Act (ECOA) and Regulation B to establish special purpose credit programs to meet the credit needs of specified classes of persons. The statement focuses on the special purpose credit options under ECOA and Regulation B, which have been publicly committed by many financial institutions to better serve underserved communities.

CFPB Issues Guidance for PSLF Communications

Adam Witmer
Regulatory Update

On 2/18/2022, the CFPB issued a Compliance Bulletin and Policy Guidance regarding the servicing of Federal student loans, including Federal Family Education Loan Program and Perkins loans, for borrowers who may be eligible for Public Service Loan Forgiveness (PSLF). The Limited PSLF Waiver announced by the Department of Education on October 6, 2021 significantly changes the program’s eligibility criteria for a limited period. Thus, servicers should consider taking certain actions to ensure compliance with the Dodd-Frank Act’s prohibition on unfair, deceptive, or abusive acts or practices.

VIDEO: What is an Error under Regulation E

VIDEO: What is an Error under Regulation E

Adam Witmer
Regulation E

In this Compliance Clip (video), Adam discusses what an error is for purposes of Electronic Fund Transfer Act, for Regulation E and for dispute purposes. In just under 8 minutes, this video takes a pretty deep dive into a core element of Regulation E disputes. This would be a great video to pass on to anyone needing to understand an “error” under Regulation E. A transcript of this video is now available.

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