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Financial Services Law Insights and Observations

CFPB Publishes Fall 2016 Rulemaking Agenda

Federal Issues Consumer Finance CFPB HMDA TRID Agency Rule-Making & Guidance

Federal Issues

On December 2, the CFPB published its Fall 2016 Statement of Regulatory Priorities, and its Fall 2016 rulemaking agenda, addressing current and future rulemakings in accordance with its obligations under the Regulatory Flexibility Act. In its Agenda, the Bureau notes, among other things, that: (i) publication of a final Arbitration rule is expected in February 2017; (ii) the Bureau intends to finalize proposed amendments to TRID by March 2017; and (iii) the Bureau plans to release in March 2017 a proposed set of technical corrections to the HMDA reporting requirements and proposed amendments to Regulation B “to clarify how financial institutions and creditors subject to Regulation C and Regulation B may comply with both regulations.” There was no next step identified for the proposed rule on payday loans and deposit advance products.

In a corresponding blog post, the Bureau provided a brief status update and overview of its various rulemakings, which are grouped into pre-rule, proposed rule, final rule, long-term, and completed stages. The CFPB noted that it anticipates that the next “larger participant” rulemaking will focus on the markets for consumer installment loans and vehicle title loans, including whether to impose registration requirements on non-depository lenders.