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#1633359 - 11/30/11 01:34 AM CFPB Request for Comment - Inherited Regs
Kathleen O. Blanchard Offline

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The CFPB has submitted for publication in the Federal Register a request for comment from "the public for streamlining regulations it recently inherited from other Federal agencies. This Notice asks the public to identify provisions of the inherited regulations that the Bureau should make the highest priority for updating, modifying, or eliminating because they are outdated, unduly burdensome, or unnecessary. The Notice discusses several specific requirements that may warrant review. It also seeks suggestions for practical measures to make complying with the regulations easier."

http://www.consumerfinance.gov/wp-content/uploads/2011/11/Streamlining_Notice_1129.pdf
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General Discussion
#1633360 - 11/30/11 01:39 AM Re: CFPB Request for Comment - Inherited Regs Kathleen O. Blanchard
Kathleen O. Blanchard Offline

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Also, 14 laws are being moved to Chapter X of Title 12, the CFPB:

The Consumer Leasing Act, the Electronic Fund Transfer Act (except with respect to Section 920 of that Act), the Equal Credit Opportunity Act, the Fair Credit Reporting Act (except with respect to Sections 615(e) and 628 of that act), the Fair Debt Collection Practices Act, Subsections (b) through (f) of Section 43 of the Federal Deposit Insurance Act, Sections 502 through 509 of the Gramm-Leach-Bliley Act (except for Section 505 as it applies to Section 501(b)), the Home Mortgage Disclosure Act, the Real Estate Settlement Procedures Act, the S.A.F.E. Mortgage Licensing Act, the Truth in Lending Act, the Truth in Savings Act, Section 626 of the Omnibus Appropriations Act, 2009, and the Interstate Land Sales Full Disclosure Act.
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#1633393 - 11/30/11 12:29 PM Re: CFPB Request for Comment - Inherited Regs Kathleen O. Blanchard
rlcarey Offline
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Great! 20 years of memorizing specific regulatory citations will be vaporized. I think I am going to retire smile
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#1633408 - 11/30/11 01:33 PM Re: CFPB Request for Comment - Inherited Regs rlcarey
RR Joker Offline
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This sounds like a complete cluster xxx waiting to happen. What a mess this could be!
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#1633409 - 11/30/11 01:36 PM Re: CFPB Request for Comment - Inherited Regs RR Joker
Kathleen O. Blanchard Offline

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Maybe they should leave these regularly used regs and switch the FRB and the CFPB in the CFR! laugh Of course, some of the other FRB regs are referred to all the time as well but not quite as much as these. (And of course RESPA will move from HUD.) But it had to happen, and actually was expected. I will need a huge chart!
Last edited by Kathleen B; 11/30/11 01:37 PM.
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#1633485 - 11/30/11 03:01 PM Re: CFPB Request for Comment - Inherited Regs Kathleen O. Blanchard
cbinder63 Offline

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It'll be simple now - Chapter X.
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#1633492 - 11/30/11 03:08 PM Re: CFPB Request for Comment - Inherited Regs cbinder63
Burgess Offline
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CRA - will CRA be moved to the Bureau?
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#1633494 - 11/30/11 03:09 PM Re: CFPB Request for Comment - Inherited Regs cbinder63
Kathleen O. Blanchard Offline

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I meant for the individual line item citations such as each requirement under Reg Z. If all that changes is the chapter number, that will be great. If the Subchapter and part numbers change, it will be a big conversion in our heads.

But this is speculation. We will see how they convert the info.
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#1633507 - 11/30/11 03:21 PM Re: CFPB Request for Comment - Inherited Regs Kathleen O. Blanchard
Ted Dreyer Offline
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My hope is that for all the transferred regulations that are currently the FRB's "lettered" regulations, that, for example, they just make the FRB's Regulation B the CFPB's Regulation B with a similar numbering system. That would minimize the changes for those regs and keep the familiar lettering terminology.

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#1633509 - 11/30/11 03:23 PM Re: CFPB Request for Comment - Inherited Regs Ted Dreyer
Kathleen O. Blanchard Offline

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I hope so too. That would be simplest. And since the Fed's Reg D does not transfer over, there is no conflict with the CFPB Reg D. The others can fall into place around it.
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#1633533 - 11/30/11 03:42 PM Re: CFPB Request for Comment - Inherited Regs Kathleen O. Blanchard
rlcarey Offline
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What's with Chapter X anyway? First FinCEN and now this??? I feel like this has something to do with the X Files or something smile
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#1633539 - 11/30/11 03:45 PM Re: CFPB Request for Comment - Inherited Regs rlcarey
Kathleen O. Blanchard Offline

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It was available?
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#1633603 - 11/30/11 04:37 PM Re: CFPB Request for Comment - Inherited Regs Kathleen O. Blanchard
NU Rhules Offline
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X Files....the Tin foil hat discussion is in that other forum. smile
This could be a mess, but hopefully they have a big white board and some cool heads helping to keep it organized as they take inputs and reduce both agency overlapping regs and confusion. Looking forward to a reg combing RESPA and TIL. Also for clarification, today they only issued a Draft Notice as part of their press release. The actual Fed Reg publication will be in about 5-7 days. You can always tell the real NPRM or Notice - it has the actual Comment period defined.

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#1633607 - 11/30/11 04:39 PM Re: CFPB Request for Comment - Inherited Regs NU Rhules
Kathleen O. Blanchard Offline

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That's why I said they had submitted for publication in the Federal Register! All that will change will be the date of publication and resulting comment period. Might as well start reading now.

I think we should all be glad of an opportunity for improving things.
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#1635147 - 12/05/11 01:36 PM Re: CFPB Request for Comment - Inherited Regs Kathleen O. Blanchard
John Burnett Offline
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The Notice and request for information was published in today's Federal Register (12/5/11), 76 FR 75825. There's a 90-day comment period ending March 5, 2012 to be followed by a "comment on the comments" period of 30 days, ending (at least for now) on April 3, 2012.

Readers and commenters, start your engines!
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#1635157 - 12/05/11 01:57 PM Re: CFPB Request for Comment - Inherited Regs Burgess
John Burnett Offline
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Originally Posted By: burgess
CRA - will CRA be moved to the Bureau?


CRA isn't a consumer protection law, and it's used in making branch, merger and acquisition application decisions. It is not one of the 14 consumer laws being transferred to the Bureau.
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