CFPB Rescinds Seven Pandemic Related Policy Statements

John Zasada, Compliance Consulting Director, Financial Institutions Group

On March 31, 2021, the Consumer Financial Protection Bureau (CFPB) announced it is rescinding seven policy statements issued in 2020. All of the policy statements were issued because of the pandemic and provide regulatory flexibility to financial institutions. The seven rescissions, effective April 1, signal a return of the CFPB to exercising its full supervisory and enforcement authority.

Here are the policy statements being rescinded:

• Statement on Bureau Supervisory and Enforcement Response to COVID-19 Pandemic  (March 26, 2020)
• Statement on Supervisory and Enforcement Practices Regarding Quarterly Reporting Under the Home Mortgage Disclosure Act  (March 26, 2020)
• Statement on Supervisory and Enforcement Practices Regarding CFPB Information Collections for Credit Card and Prepaid Account Issuers  (March 26, 2020)
• Statement on Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act  (April 1, 2020)
• Statement on Supervisory and Enforcement Practices Regarding Certain Filing Requirements Under the Interstate Land Sales Full Disclosure Act (ILSA) and Regulation J  (April 27, 2020)
• Statement on Supervisory and Enforcement Practices Regarding Regulation Z Billing Error Resolution Timeframes in Light of the COVID-19 Pandemic  (May 13, 2020)
• Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic  (June 3, 2020)

If you have any questions about how this may impact your financial institution, please contact Doeren Mayhew’s regulatory compliance specialists.