In separate actions this week, the CFPB issued a statement on enforcement practices regarding electronic credit card disclosures amid the pandemic and steps related to facilitating the LIBOR transition.
The agency announced that it is providing “temporary and targeted flexibility” for credit card issuers regarding the electronic provision of certain disclosures required to be in writing during this pandemic. The action also is an effort to help consumers receive relief during the pandemic more quickly from their credit card issuer.
CFPB “recognizes the serious impact the COVID-19 pandemic is having on the financial lives of many consumers and on the operations of many supervised entities, including credit card issuers subject to TILA (15 U.S.C. 1601 et seq.), which is implemented by the Bureau’s Regulation Z (12 CFR part 1026),” requiring that creditors provide written disclosures to consumers for account-opening and temporary rate or fee reduction.
The statement on supervisory and enforcement practices regarding electronic credit card disclosures amid the COVID-19 pandemic can be accessed by clicking here.
And in an effort to facilitate the transition away from LIBOR for consumers and regulated entities, the CFPB released an updated Consumer Handbook on Adjustable Rate Mortgages to help consumers better understand adjustable rate mortgage loan products. The agency also released a notice of proposed rulemaking concerning the anticipated discontinuation of LIBOR, including proposing examples of replacement indices that meet Regulation Z standards.
Additionally, the agency is issuing guidance on other LIBOR transition topics that do not require amendments to Regulation Z. More information about the steps being taken to facilitate the LIBOR transition can be found on the CFPB website.
CFPB also announced changes in disclosure provisions for open-end and closed-end loan products to provide examples of replacement indices for LIBOR, expected to be discontinued after 2021. More information can be accessed by clicking here.