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CFBP Signals Early 2017 Actions

Mon, Dec 5, 2016

Columbia, Maryland

Capitol Hill continues to buzz with talk about regulatory reform and changes to the CFPB. The Bureau has recently released it proposed rulemaking agenda for the next year, which anticipates action on arbitration and debt collection in early 2017, and pre-rule activity on overdraft in January 2017 among other issues.  On Overdraft, the CFPB is “continuing to engage in additional research and has begun consumer testing initiatives relating to the opt-in process. The CFPB will be releasing additional research in early 2017 that focuses on smaller financial institutions.”

On Overdraft, the Association has sent to all members a survey about ODP offered at their respective credit unions. The data received in response will assist in guiding our agenda and providing aggregate data to educate the CFPB as they continue their internal discussions.  Through CEO Roundtables and system wide, we have maintained a strong focus over the past two years to educate the CFPB about how consumers use overdraft, and why many of them prefer and choose this service as an option. We believe these efforts have moved the bureau to more fully analyze this issue and pushed back its original timeline for promulgating rules. We would ask for your survey responses ASAP.

On other issues:

  • Arbitration: Final rule is projected for February 2017
  • Debt Collection: Pre-rule activity projected for February 2017; it could be for the proposed rule for third-party debt collection or the SBREFA panel for first parties.
  • TRID Fix: Final rule expected March 2017
  • Payday and Small Dollar Loans (No additional information about timing of final rule)  

One large caveat on projected timelines on the CFPB rulemaking agenda, particularly this year will be the agenda and focus of the new administration taking office in January. 

Contact: Glen Cooney, 443-325-0775,