On January 5, 2024, the CFPB published an issue spotlight on the CFPB’s oversight of student loan servicing practices in the early months of the resumption of federal student loan repayments after over three years of a payment pause due to the COVID-19 emergency. The report shows that borrowers are encountering long hold times when trying to reach their student loan servicer, experiencing significant delays in application processing times for income-driven repayment plans, and receiving inaccurate billing statements and disclosures.

Our team at the Compliance Cohort was able to slow down a bit for the holidays, but we are back at it this week and excited about where we are heading in 2024. Over the coming months, we have several new programs planned, starting with our upcoming Winter 2024 Quarterly Compliance Update that will include an overview of the new CRA rule. While the CRA class will be included in our Winter 2024 Quarterly Compliance Update and available to all premium members, it will also be available as a stand-alone class. This program will cover an overview of the new CRA rule that applies to banks, focusing in on how it will affect small and mid-sized banks - so be sure to keep an eye out for more information about this program in the coming weeks. Also in the coming weeks, you will begin to see information about becoming a premium member of the Compliance Cohort. The enrollment period for our premium memberships only happens twice a year (Jan/Feb and July/Aug), so this will be your opportunity to enroll for all of 2024 as a premium member. Speaking of which, we are currently holding a contest to give away one enrollment to our Premium Pro membership - which gives you access to ever single training program in our store - so be sure to find the information on this huge giveaway below and enter for your chance to win. It really is amazing to us how fast 2023 went, but we are excited to roll into 2024 and see what great things will happen in the wonderful world of banking compliance. Happy New Year! -The Compliance Cohort Team-

On January 2, 2024, the CFPB announced through a blog post that it has filed an amicus brief in the U.S. Court of Appeals for the First Circuit to help ensure consumers can hold debt collectors responsible when they make false representations. The CFPB reiterates that it is a violation against Fair Debt Collection Practices Act to tell consumers that they owe a debt or an amount of money that they don’t actually owe, particularly in medical debt collection.

On December 20, 2023, the ABA banking Journal reported that President Biden vetoed a Senate joint resolution to overturn the CFPB’s final rule implementing Section 1071 of the Dodd-Frank Act, also known as the small business lending data collection rule. In a published statement, Biden said that the resolution would harm all those that stand to benefit from expanded transparency and accountability, thus vetoing the resolution.

On December 21, 2023, FinCEN issued a final rule that establishes the framework for access to and protection of beneficial ownership information (BOI). The final rule prescribes the circumstances under which BOI reported in compliance with FinCEN’s September 30, 2022 final BOI Reporting Rule may be disclosed to Federal agencies; state, local, tribal, and foreign governments; and financial institutions, and how it must be protected. 

On December 20, 2023, the CFPB and the DOJ sued Colony Ridge, a Texas-based developer and lender, for operating an illegal land sales scheme and targeting tens of thousands of Hispanic borrowers with false statements and predatory loans. The lawsuit alleges that Colony Ridge sells unsuspecting families flood-prone land without water, sewer, or electrical infrastructure, and that the company sets borrowers up to fail with loans they cannot afford.