CFPB Posts Fall Rulemaking Agenda
November 24, 2014 – The Consumer Financial Protection Bureau released its Fall 2014 rulemaking agenda on Friday, November 21, 2014 in conjunction with the Office of Management and Budget’s (OMB) Unified Agenda of Regulatory and Deregulatory Actions. The Unified Agenda is published in the Federal Register twice a year to give the public some insight into federal agency priorities for the coming months.
The Bureau highlighted several key areas of focus in its Fall Agenda, including prepaid cards, payday loans, debt collection and overdraft services. Implementation of the TILA/RESPA Integrated Disclosure rule (TRID Final Rule), which is effective August 1, 2015 was also listed as a priority. The Bureau proposed technical corrections and amendments to the TRID Final Rule in October 2014, and is working to finalize those amendments quickly in order to give industry adequate time to implement them before the effective date.
In November 2014, the Bureau released a proposed rule that would provide comprehensive consumer protections for prepaid financial products. The proposed rule would extend Regulation E protections requiring certain disclosures and error resolution rights to prepaid products, and would cap liability for unauthorized use of prepaid cards under certain conditions. For prepaid products with credit or overdraft features, the proposed rule would extend some Regulation Z protections, including Regulation Z’s credit card rules.
The Fall Agenda reiterated the Bureau’s intent to tackle rules for payday lending products, debt collection, and overdraft services. The Bureau noted the extensive research that they have conducted in these areas, that additional research was planned, and that potential rulemaking might address disclosures and acts and practices in connection with these products.