Perhaps a Sign of Things to Come

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2 Responses

  1. Ken Rhodes says:

    Michelle — I am puzzled (a little) by this game of “hot potato” regarding Reg Z. I guess my confusion originates with the opening text of the regulation:

    Subpart A—General

    § 226.1 Authority, purpose, coverage, organization, enforcement and liability.

    (a) Authority. This regulation, known as Regulation Z, is issued by the Board of Governors of the Federal Reserve System to implement the federal Truth in Lending Act, which is contained in title I of the Consumer Credit Protection Act, as amended (15 U.S.C. 1601 et seq.).
    The paragraph titled “Authority” does not explicitly state the authority, but merely implies that it passed to the Fed from the legislation. If, in fact, that authority was assigned by the legislation, then does the Fed have it in their purview to delegate it to another agency?

    OTOH, it seems to me that your third paragraph emphasizes the intent of Congress, which is to consolidate consumer protections under the CFPB. If that seems in conflict with the desires of many in the mortgage industry, well — tough luck, Sparky. Shoulda done your homework better.

  2. Michelle Harner says:

    Ken: Thanks so much for the comment. I think the intent and directive to consolidate consumer oversight in a single agency stems from the Dodd-Frank Act itself, which the regulation does not reference (other than in a footnote). It is a curious game indeed, particularly since the Federal Reserve knows that the transition is on the horizon. I have attached another great overview of Dodd-Frank’s provisions concerning the CFPB below. Best regards, Michelle.