Small Business Lending Data Collection Under the Equal Credit Opportunity Act

On September 1, 2021, the CFPB published proposed rulemaking on small business lending data collection. The proposal would require covered financial institutions to annually collect and report to the Bureau data on credit applications for small businesses, including those that are owned by women or minorities. The proposed rule is 918 pages long. The CFPB also provides a table of … Read More

CFPB announces new requirements for submitting credit card agreements

Last Friday, the CFPB provided information on new data submission requirements for uploading credit card agreements to the CFPB. We have reprinted the bulletin below for your convivence. Credit card issuers who are required to make quarterly credit card submissions to the Bureau pursuant to 12 CFR 1026.58(c) – 10,000 or more open credit card accounts as of the last … Read More

June’s Regulatory Recap

June’s Regulatory Recap is now available here.  Let us know if we can help in any way. Have you seen our Weekly Rewinds?  Past editions are available on our Resources page.   Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized … Read More

July’s Regulatory Recap

July’s Regulatory Recap is now available here.  Let us know if you have questions or if we can help in any way. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of … Read More

Consumer Compliance Outlook

The Federal Reserve issued its first 2020 issue of its Consumer Compliance Outlook. As always, the issue is a good resource for compliance folks. It contains information on regulatory updates, federal court opinions, and commonly cited violations. Included in the violations are violations regarding: spousal signature requirements under Regulation B and evidence of joint intent – especially conflicts between community … Read More

February’s Regulatory Recap

February’s Regulatory Recap is now available here.  Let us know if you have questions, or if we can be of any service. Please be advised that CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of … Read More

CFPB Supervisory Highlights – Winter 2020… and how CSG can help

In February, the CFPB released its 21st Supervisory Highlights Report. This report covered findings identified in examinations conducted by the CFPB between April 2019 and August 2019. Areas included in the report include mortgage servicing, payday lending (including general Regulation Z requirements), debt collection, and student loan servicing. Mortgage Servicing Highlights Regulation X violations discussed in the report include failing … Read More

November’s Regulatory Recap

November’s Regulatory Recap is now available here.  If you have questions, please let us know. Law-Related Services Disclaimer.  Please be advised, CSG provides financial services compliance audit and consulting services to our clients.  The services that we provide include certain tasks that may be characterized as “law-related services” under Rule 5.7 of the Rules of Professional Conduct governing lawyers.  Since … Read More

Alternative Data in Credit Underwriting

The Federal Reserve, CFPB, FDIC, NCUA, and OCC released an Interagency Statement on the Use of Alternative Data in Credit Underwriting.  The statement focuses on the consumer protection implications of the use of alternative data (information not typically found in a credit report) in underwriting, while highlighting potential benefits and risks associated.  One method of alternative data included in the … Read More

CFPB Extends the 500 open-end lines of credit threshold to January 1, 2022

On October 10, 2019, the CFPB announced that it issued a final rule extending the current temporary threshold of 500 open-end lines of credit for open-end institutional and transactional coverage. For data collection years 2020 and 2021, financial institutions that originated fewer than 500 open-end lines of credit in either of the two preceding calendar years will not need to … Read More