Author name: Keith Schostag

CFPB Enforcement Action Highlights Consequences of HMDA Errors

Compliance / / / 2 minutes of reading

On June 18, 2024, the Consumer Financial Protection Bureau (CFPB) filed a stipulated final judgment against Freedom Mortgage Corporation (Freedom) for alleged violations of the Home Mortgage Disclosure Act (HMDA), Regulation C, and the Consumer Financial Protection Act. Financial institutions, including credit unions, are required to comply with HMDA and Regulation C if they meet …

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Are Unlawful Terms in Your Contract a Deceptive Act or Practice?

Compliance / / 4 minutes of reading

On June 4, 2024, the Consumer Financial Protection Bureau (CFPB) released Consumer Financial Protection Circular 2024-03 (Circular). The Circular discusses whether having unlawful and/or unenforceable terms and conditions in a contract for consumer financial products and services are a violation of the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices. The short …

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Consider Immigration Status Carefully

Compliance / / 3 minutes of reading

Does your credit union offer loans? If so, have you looked at your underwriting requirements recently? Specifically, what weight does the credit union give an applicant’s citizenship status? The Equal Credit Opportunity Act (ECOA) and Regulation B, section 1002.2(z) prohibits discrimination based on national origin. However, under section 1002.6(b)(7): “A creditor may consider the applicant’s …

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CFPB Releases Circular on Deceptively Marketing Remittance Transfers

Compliance / / / 4 minutes of reading

On March 27, 2024, the Consumer Financial Protection Bureau (CFPB) released Consumer Financial Protection Circular 2024-02 (the circular). The circular discusses the Consumer Financial Protection Act’s (CFPA) prohibition on deceptive acts or practices when marketing the cost and/or speed of sending remittance transfers. To those unfamiliar with deceptive acts or practices, under the CFPA, a …

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FinCEN Updates PPP FAQ Clarifying Permission to Acknowledge Filing of a SAR to SBA

Compliance / / 3 minutes of reading

Happy January 18th everyone. It’s national Michigan day! Fun fact about America’s Credit Unions’ compliance team, one third of our team members live in Michigan. Did you know, people who live in Michigan are called Michiganders. Did you also know that on January 12, 2024, FinCEN released an updated Paycheck Protection Plan (PPP) FAQ? Specifically, …

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