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Consumer Financial Protection Bureau (CFPB)
The CPFB announced that, with respect to the regulation titled Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders, it will not prioritize enforcement or supervision actions on entities that do not satisfy future deadlines under the regulation to submit registration information. This policy applies to, but is not limited to, the upcoming April 14, 2025, and July 14, 2025, registration deadlines. The Bureau will instead continue to focus its enforcement and supervision activities on pressing threats to consumers. The Bureau is further considering issuing a notice of proposed rulemaking to rescind the regulation or narrow its scope.
CFPB Moves to Enter a Consent Judgment Regarding $8 Credit Card Late Fee Cap
The CFPB entered a joint motion with the U.S. District Court of Northern District of Texas. The consent judgement vacates the Late Fee final rule which capped the late fees large financial institutions could charge at $8. This means the existing Credit Card Act safe harbor penalty fee amounts in Regulation Z still stand and are not changed.
The consent order also dismisses the other claims presented as part of the lawsuit against the CFPB.
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Financial Crimes Enforcement Network (FinCEN)
FinCEN Renews Residential Real Estate Geographic Targeting Orders
FinCEN announced the renewal of its Geographic Targeting Orders (GTOs) that require U.S. title insurance companies to identify the natural persons behind shell companies used in non-financed purchases of residential real estate.
The GTO does not apply to credit unions since they are already complying with the beneficial ownership rules which already require credit unions to identify the beneficial owners of legal entity members, including those of shell companies that own the legal entity members.
FinCEN renewed the GTOs that cover certain counties and major U.S. metropolitan areas in California, Colorado, Connecticut, Florida, Hawaii, Illinois, Maryland, Massachusetts, Nevada, New York, Texas, Washington, Virginia, and the District of Columbia. No changes have been made to jurisdictional coverage since the last issuance of these GTOs. The purchase price threshold likewise remains $300,000 for each covered metropolitan area, with the exception of the City and County of Baltimore, where the purchase price threshold is $50,000.
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