The Consumer Financial Protection Bureau is amending Regulation C under the Home Mortgage Disclosure Act (“HMDA”), extending the current temporary threshold for collecting and reporting data about open-end lines of credit until January 1, 2022. The rule also incorporates partial exemptions from the Economic Growth, Regulatory Relief, and Consumer Protection Act (“EGRRCPA”), which Congress enacted in 2018.   The HMDA requires individual depository institutions and for-profit businesses to report data about originations and purchases of mortgage…

With oversight from the Securities and Exchange Commission, the Financial Industry Regulatory Authority is preparing revisions to its rules aimed at amending the process for expungement filings and hearings. FINRA believes its new rules will increase the level of scrutiny on licensed brokers and financial advisors seeking to erase customer complaints from their regulatory records.  By way of background, in order to promote market transparency to the public, FINRA maintains the Central Registration Depository (“CRD”),…

The Consumer Financial Protection Bureau is proposing changes to the Fair Debt Collection Practices Act and the Dodd-Frank Wall Street Reform and Consumer Protection Act (commonly referred to as “Dodd-Frank”). State attorneys general from 28 states have banded together to comment on the changes, which may impact an estimated 49 million American consumers who are contacted each year by debt collectors.    The proposed rule changes would allow debt collectors to use social media as a form…

The Telephone Consumer Protection Act, while permitting personal liability against officers and directors, continues to shield related corporate entities from liability. The same corporate formalities that impose liability on officers and directors ironically work to shield corporate entities from the same liability.   In Holland v. JPMorgan Chase Bank, plaintiff Steven W. Holland sued two different banking entities: JPMorgan Chase Bank, N.A., and Chase Bank USA, N.A., alleging that in 2012 they used an automated dialing…