John Zasada, Compliance Consulting Director, Financial Institutions Group

On March 26, 2020, the Consumer Financial Protection Bureau (CFPB) announced it is temporarily relaxing a few requirements under the Home Mortgage Disclosure Act (HDMA), Regulation Z and Regulation E. The CFPB will not expect, until further notice, quarterly HMDA reporting as is normally required for financial institutions that report for the preceding calendar year at least 60,000 covered loans and applications (excluding purchased loans). The CFPB also announced it will not cite as a violation, or initiate an enforcement action, failure to provide the following information related to credit cards and prepaid accounts:

  • Annual submission of certain information concerning agreements between credit card issuers and institutions of higher education (and certain affiliated organizations), as required by Regulation Z, 12 CFR 1026.57(d)(3);
  • Quarterly submission of consumer credit card agreements, as required by Regulation Z, 12 CFR 1026.58(c);
  • Collection of certain credit card price and availability information from a sample of credit card issuers under the Truth in Lending Act, 15 USC §1646(b)(1) et seq.; and
  • Submission of prepaid account agreements and related information required by Regulation E, 12 CFR 1005.19(b).