CFPB Provides Flexibility During COVID-19 Pandemic

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Article Highlights:

On March 26, 2020, the Consumer Financial Protection Bureau (CFPB) released three statements to provide flexibility to financial companies during the COVID-19 pandemic.

First, the CFPB announced that it will not cite institutions in examinations or initiate enforcement activity for failures to begin quarterly submissions of Home Mortgage Disclosure Act (HMDA) data. For lenders with at least 60,000 covered loans and applications (other than purchased loans) in 2019, the first quarterly submission is due by May 30, 2020. The CFPB will provide further information on resumption of quarterly HMDA reporting at a later date. The CFPB also reminded institutions that the existing safe harbor for good faith efforts for timely and complete reporting applies to lenders subject to quarterly submissions, meaning inaccuracies or omissions in first quarter HMDA data do not have to be corrected until the annual HMDA data submission by March 1, 2021.

Similarly, the CFPB stated it does not intend to cite institutions in examinations or initiate enforcement activity for failures by credit card and prepaid card issuers to make certain annual and quarterly information submissions required under the Truth in Lending Act, Regulation Z, and Regulation E. The CFPB will provide further information on resumption of these submissions at a later date.

Third, the CFPB reiterated its prior encouragement to financial institutions to work constructively to meet borrower and customer needs during the pandemic. To promote institutional abilities to do so during a time of great disruption, the CFPB announced it will work closely with affected institutions and consider current staffing and other resource challenges in scheduling examinations and other supervisory activities.

Finally, the CFPB postponed two data collections associated with rulemaking activities:

  • A survey of the expected cost of compliance with pending rulemaking on small business loan data collection under Section 1071 of the Dodd-Frank Act; and
  • A survey of firms providing Property Assessed Clean Energy financing required under Section 307 of the Economic Growth, Regulatory Relief, and Consumer Protection Act.

For additional information on addressing issues related to COVID-19, please refer to the following:



Lynn Woosley

Lynn Woosley is a Senior Director with Treliant.  She is a seasoned executive with extensive risk management experience in regulatory compliance, consumer and commercial credit risk, credit and compliance risk modeling, model governance, regulatory change management, acquisition due diligence, and operational risk in both financial services and regulatory environments.