Here are the current Consumer Financial Protection Bureau updates as of March 11, 2013:
CUNA Files Comments With CFPB On TILA/RESPA Forms Testing
Late last week, the Credit Union National Association (CUNA) filed a comment letter with the Consumer Financial Protection Bureau (CFPB) on the agency’s proposed quantitative testing of its combined forms. The Bureau is required to combine certain Truth in Lending and Real Estate Settlement Procedures Act forms and disclosures under the Dodd Frank Wall Street Reform and Consumer Protection Act. CUNA continues to meet and discuss with the Bureau to advocate for clear and understandable consumer disclosures. CUNA remains steadfast in its advocacy efforts to stress to the Bureau, the importance of implementing the TILA/RESPA rulemaking process, with an emphasis on minimizing the regulatory burdens on credit unions.
According to the CFPB’s Unified Agenda, the agency anticipates finalizing its TILA/RESPA rulemaking in September of this year. However, as their comment letter indicates, the Bureau’s proposed timing of the testing of its TILA/RESPA forms will be ongoing through 2013 and into 2014. CUNA has raised concerns about this proposed timeline, as well as the content of the testing methodology.
CFPB Survey on Financial Services Marketed to Higher Education Students
The CFPB seeks “information on how current and future partnerships or other arrangements between institutions of higher education (including their affiliated entities) and financial institutions could be structured to promote positive financial decision-making among young consumers.” The CFPB also seeks information to develop a clearer picture of the financial products and services that are being offered to college students, as well as consumers’ experiences using those products and services. We request that members provide us information on the services and products they offer that are detailed by the CFPB document. CUNA’s Comment Call can be found here and CFPB’s Federal Register notice can be found here. Please submit comments to CUNA by March 14, 2013.