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Compliance

CFPB Hurricane Harvey Updates

The CFPB issued a statement encouraging its supervised entities to aid consumers, to the extent possible and consistent with applicable law, and provided examples and advice on how to best lessen the negative impact on borrowers who may be at financial risk due to Hurricane Harvey.

For example, supervised entities should:

  • Make best efforts to staff sufficiently in order to address consumers’ needs
  • Offer penalty-free forbearance or repayment periods with clearly disclosed terms;
  • Limit or waiving fees and charges
  • Restructure existing debt by, for example, extending repayment terms with clearly disclosed terms;
  • Refinance existing debt or extending new credit with terms favorable to the consumer. Terms could, for example, reduce costs, limit payment amounts, or offer consumers other flexibility;
  • Ease documentation or credit-extension requirements;
  • Increase capacity for customer service hotlines, particularly those that serve consumers in languages other than English

In addition, the Bureau spotlights a few examples of existing regulatory flexibility from Regulation B, X, and Z, and advises supervised entities to employ relief options that best suit consumers affected by a major disaster or emergency.

The Bureau also acknowledged that supervised entities might be experiencing hardships. “Supervised entities may themselves experience difficulties due to a major disaster or emergency. To that end, when conducting examinations and other supervisory activities, the Bureau will consider that circumstances that supervised entities may face following a major disaster and will be sensitive to good faith efforts to assist consumers,” the Bureau stated.

Please visit our website to review the other recent industry updates related to Hurricane Harvey.

Proctor will continue to monitor federal, state and investor requirements for Hurricane Harvey assistance and will provide updates as they develop.