CFPB ATR/QM Rule Assessment
What's in store for the CFPB's Ability-to-Repay/Qualified Mortgage rule ("ATR/QM Rule")? The agency assessed the Rule (consisting of the January 2013 Final Rule and subsequent amendments) as required by the Dodd-Frank Act, and reviewed whether the rule is meeting its (and the agency's) objectives or creating unintended consequences. The CFPB sought public comment in May 2017 as it assessed the effectiveness of the ATR/QM Rule. The 2013 Ability-to-Repay and Qualified Mortgage Assessment Report ("Report") was made available on January 10, 2019.
Broad Coalition of State Attorneys General Urges Military Lending Protection
A broad and bipartisan coalition of 33 state AGs recently sent a letter to the Consumer Financial Protection Bureau regarding the Military Lending Act (MLA). While the letter's main purpose is to dissuade the Bureau from eliminating its own supervisory exams into MLA compliance, the letter also provides important insight into states' enforcement priorities.
FTC 2019 Insights and Priorities for the Payments Industry
After a busy 2018, the FTC has lost no time in making known its investigation and enforcement priorities for 2019. In a recent blog post, the FTC highlighted the areas that will likely guide its enforcement priorities for the remainder of the year.
Federal Reserve Board Proposes Tailoring Prudential Standards, Suggests More to Come
Last October, the Board of Governors of the Federal Reserve System released two notices of proposed rulemaking to tailor prudential standards for certain banking organizations, the second of which was issued jointly with the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation (together, "Proposal"). The Proposal, in part, implements section 401 of S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act.
Mastercard Targets Negative Options In 2019 – Demands Transparency
As 2019 goes into full swing, it's important for providers of payment processing services (referred to here as "acquirers") and their merchants or submerchants to prepare for the various regulatory and industry changes coming this year. One such significant change comes in the form of Mastercard's updated rules for negative option billing programs.