Nov. 17: CFPB Updates This Week
CFPB Report Highlighting Consumer Protection Issues in Medical Debt Collection
The Consumer Financial Protection Bureau (CFPB) issued a report highlighting the challenges American families face when debt collectors pursue allegedly unpaid medical bills. Discussing the 8,500 complaints submitted in 2022 by servicemembers, older adults, and other consumers relating to medical debt collections, the CFPB’s annual report to Congress on the Fair Debt Collection Practices Act describes how the CFPB and states have worked to stop the collections of medical bills that are inaccurate or not even owed at all. The report also provides updates on the debt collection market more broadly and summarizes activities by the CFPB and other federal agencies relating to debt collection, including the Federal Trade Commission (FTC) and its actions under the FTC Act to protect small businesses from unfair and deceptive debt collection practices.
Tens of millions of people are pursued by debt collectors for medical bills, and today’s report highlights the problem of the collection of medical bills that are inaccurate or not owed. The CFPB has previously described the significant evidence, including reports from consumers themselves, that the collection, furnishing, and reporting of medical bills is plagued by inaccuracies.
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CFPB financial report fiscal year 2023
The Consumer Financial Protection Bureau released the financial report for fiscal year 2023. As required by the Dodd-Frank Act, the CFPB prepared comparative financial statements for fiscal years 2023 and 2022. The Government Accountability Office (GAO) rendered an unmodified audit opinion on our financial statements. GAO found that CFPB maintained in all material respects, effective internal control over financial reporting as of September 30, 2023. Also, GAO reported that its test for compliance with provisions of applicable laws, regulations, contracts and grant agreements disclosed no instances of noncompliance for fiscal year 2023…
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Recently, the CFPB announced several annual threshold adjustment final rules.
The first rule is a joint rulemaking between the CFPB, the Federal Reserve Board, and the Office of the Comptroller of the Currency to adjust the threshold for exempting loans from special appraisal requirements under the TILA Higher Priced Mortgage Loan Appraisal rule.
The second and third rules are joint rulemakings between the CFPB and the Federal Reserve Board to adjust the thresholds in Regulation Z and Regulation M for determining the exempt consumer credit transactions under TILA and the exempt consumer lease transactions under the Consumer Leasing Act.
The fourth rule is a CFPB rulemaking to adjust the maximum amount consumer reporting agencies may charge consumers for making a file disclosure to a consumer under the FCRA.
These adjustments are effective January 1, 2024.
- You can access the HPML threshold adjustment here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/appraisals-higher-priced-mortgage-loans-exemption-threshold-adjustments/.
- You can access the Regulation Z threshold adjustments here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/truth-lending-regulation-z-threshold-adjustments/.
- You can access the Regulation M threshold adjustments here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/consumer-leasing-regulation-m-adjustments/.
- You can access the FCRA threshold adjustment here: https://www.consumerfinance.gov/policy-compliance/rulemaking/final-rules/fair-credit-reporting-act-disclosures/.
The Federal Reserve Board and the Consumer Financial Protection Bureau today announced the dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are subject to certain Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) requirements.
By law, the agencies are required to adjust the thresholds annually based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, known as CPI-W. Transactions at or below the thresholds are subject to the protections of the regulations.
Specifically, based on the annual percentage increase in the CPI-W as of June 1, 2023, Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) generally will apply to consumer credit transactions and consumer leases of $69,500 or less in 2024. However, private education loans and loans secured by real property, such as mortgages, are subject to Regulation Z (Truth in Lending) regardless of the amount of the loan.
The Consumer Financial Protection Bureau, the Federal Reserve Board, and the Office of the Comptroller of the Currency today announced that the 2024 threshold for whether higher-priced mortgage loans are subject to special appraisal requirements will increase from $31,000 to $32,400.
The threshold amount will be effective January 1, 2024, and is based on the annual percentage increase in the Consumer Price Index for Urban Wage Earners and Clerical Workers, known as CPI-W, as of June 1, 2023.
The Dodd-Frank Act added special appraisal requirements for higher-priced mortgage loans, including that creditors obtain a written appraisal based on a physical visit to the interior of the home before making a higher-priced mortgage loan. The rules implementing these requirements contain an exemption for loans of $25,000 or less, adjusted annually to reflect CPI-W increases.