All in Regulatory Update

On October 7, 2024, the CFPB published a new edition of Supervisory Highlights describing the agency’s supervisory findings related to illegal practices in auto finance, including lenders repossessing consumers’ cars after the borrower made timely payments or received loan extensions. The report also highlights significant problems with add-on products that are packaged at the front-end of the auto loan, increasing the loan costs, and then not properly refunded at the back end upon early loan termination, when the consumer can no longer use the products.

On October 1, 2024, the OCC released its bank supervision operating plan for fiscal year 2025, which begins on October 1, 2024, and ends on September 30, 2025. The plan provides the foundation for policy initiatives and for supervisory strategies as applied to individual national banks, federal savings associations, federal branches, federal agencies, and technology service providers. The OCC staff will use this plan to guide their supervisory priorities, planning, and resource allocations.

On September 24, 2024, the CFPB issued the Office of Servicemember Affairs’ annual report for 2023 which covers the top financial concerns facing servicemembers, veterans, and military families, based on the complaints they submitted to the CFPB. The reports also identify emerging risks in consumer finance and provide an update on the CFPB’s efforts toward continuing to protect the military community from harmful financial products and practices.

On September 20, 2024, the CFPB issued a proposed rule with a narrow amendment to disclosure requirements for certain international money transfers, or remittances. The proposed change aims to ensure that consumers sending a remittance transfer have information about the types of inquiries that may be most efficient to direct to the CFPB and the State agency that licenses or charters their remittance transfer provider.