Contents:

- INTRODUCTION

- ABOUT THE FIRM/ABOUT THE CONSUMER FINANCIAL SERVICES GROUP

I. RULEMAKING

A. Mortgage Market CFPB Wades Through QM... 4

Bureau Gives Mortgage Industry a Pleasant Surprise with Interim Parity Act Rules... 6

The CFPB and Fair Lending: Expectations for the Coming Year... 8

Loan Originator Compensation on the CFPB’s Birthday – It’s Seven Years in Dog Years ... 10

Industry Anticipates Additional Appraisal Reform... 14

CFPB Proposes Regulations to Combine RESPA and TILA Mortgage Disclosures: Buckle Up for the Long-Anticipated Ride... 17

CFPB Will Use Rulemaking Authority to Establish Mortgage Servicing Standards... 21

Forget Plain Vanilla – How About Pickle? Proposed HOEPA Rule Threatens to Curtail Consumer Credit... 23

B. Other Markets CFPB Supervision of Nonbank Covered Persons Posing Risks to Consumers ... 31

CFPB Issues Proposed Rule Detailing Supervisory Powers Over Larger Debt Collectors and Finalizes Rule on Supervision of Larger Consumer Reporting Agencies ... 34

Bureau Begins Rulemaking Process for GPR Cards... 37

“Know Before You Owe” and the CFPB’s Attempts at Improving Student Loan and Credit Card Disclosures ... 39

C. Challenging Rulemaking

Holding the Bureau’s Rulemaking Process to Account ...42

II. SUPERVISION AND EXAMINATION

CFPB and Federal Supervisory Agencies Issue Memorandum of Understanding on Supervisory Coordination ... 45

Regulation through Examination: An Overview of CFPB Examination Guidance ... 47

Unlucky Day? The CFPB Issues Its Vendor Management Bulletin on Friday the 13th ... 49

The Bureau’s Treatment of Confidential Supervisory Information ... 53

III. ENFORCEMENT

Maneuvering the Unchartered Seas of CFPB Investigations ... 56

CFPB Takes Steps to Encourage Whistleblowers... 61

Expeditious, Fair and Impartial? Only Time Will Tell Whether the CFPB Adjudication Process Meets the Bureau’s Stated Goals ... 62

IV. POLITICS

Can the CFPB Make It Out of the Crib? Continuing Questions About Its Legitimacy and Likely Longevity ... 65

CONSUMER FINANCIAL SERVICES PRACTICE CONTACT LIST... 69