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October

8
2024
Industry News

FDIC Announces Extension of Comment Period for Proposed Changes to its Brokered Deposit Regulations

The Federal Deposit Insurance Corporation (FDIC) is extending the comment period on its notice of proposed rulemaking (NPR) to strengthen the important prudential protections of the agency’s safety and soundness rule on brokered deposits (12 CFR 337.6) that implements Section 29 of the Federal Deposit Insurance Act.

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October

8
2024
Trends

Big Bank Lending Income Projected to Hit Two-Year Low

America’s biggest banks are reportedly ready to announce the lowest lending income in two years. J.P. Morgan Chase, Bank of America, Citigroup and Wells Fargo will release their earnings in the weeks ahead, and are expected to list a combined net interest income of a little less than $62 billion, the Financial Times (FT) reported Tuesday (Oct. 8).

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October

8
2024
Compliance

When Did You Last Review Your Consumer Contracts?

A CFPB Circular from June bears additional scrutiny from across the financial services spectrum. Despite most courts allowing “savings” clauses in contracts, the Consumer Financial Protection Bureau (CFPB) indicates that the inclusion of such provisions that are deemed “unenforceable” would render a contract unfair, deceptive, or abusive (UDAAP).

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October

8
2024
Industry News

ONE-TO-ONE CONFUSION: No You Cannot Display the Name of the Seller AFTER The Consumer Provides Consent

A bunch of folks have been asking me whether you can display the name of the seller (lead buyer) after the consumer signs the consent form. The answer is NO (or at least, probably not and I wouldn’t risk it.)* The new reg requires consent to be provided to an “identified seller.” And the agreement for consent has to provide the identified seller–which highly suggests you cannot provide the identity of the seller AFTER the agreement is signed.

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October

7
2024
Industry News

CFPB Takes Action Against Wrongful Auto Repossessions and Loan Servicing Breakdowns

Today, the Consumer Financial Protection Bureau (CFPB) published a new edition of Supervisory Highlights describing the agency’s supervisory findings related to illegal practices in auto finance, including lenders repossessing consumers’ cars after the borrower made timely payments or received loan extensions.

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