ABA Urges Congress to Protect Privileged Information Given to CFPB

The American Bar Association (ABA) has sent letters to the United States Congress advocating for passage of legislation requiring the Consumer Financial Protection Bureau (CFPB) to protect privileged information that the agency receives from banks.  The letter from the ABA to Senate and House leaders raises the same concerns expressed by banks that now fall under the new bureau's regulatory regime.  The ABA's letter argues that the CFPB should be governed by the same rules regarding protections of privileged information that other federal banking regulators must follow.

There are pending bills in both the Senate and House (H.R. 4014 and S. 2099) that, if passed, will categorize the CFPB as a federal banking regulator, thus subjecting them to the same rules as other banking regulating agencies regarding privileged information received from banks.  The Dodd-Frank Wall Street Reform and Consumer Protection Act, which created the CFPB, did not include such a provision, leading to bank concerns that sensitive information will be improperly provided to the public or competitors if produced to the CFPB.  Under current law, federal banking agencies may share with other similar agencies privileged information received from banks without a waiving the confidentiality of the information. Sharing privileged information with another third party--which may include the CFPB-- waives the confidential nature of the information.




 

Mortgage Servicing Settlement Reached

February 9, 2012.  Today government officials, including  Attorney General Eric Holder, announced a $26 billion settlement with five banks to settle allegations of mortgage servicing and foreclosure processing errors. The agreement, reached with Bank of America Corp., JPMorgan Chase & Co., Citigroup Inc., Wells Fargo & Co., and Ally Financial Inc., resolves allegations related to foreclosure practices in 2009 and 2010. According to a New York Times article, under the settlement, the banks will provide $17 billion in loan modifications for delinquent borrowers. The deal also includes about $3 billion for “underwater” borrowers to refinance their home and approximately $1 billion paid to the Federal Housing Administration. Another $5 billion includes cash payments to states and federal authorities.

The settlement, which largely provides for loan modification incentives, provides banks certainty about resolving the government's allegations in connection with paperwork errors during foreclosures initiated after borrowers defaulted on their mortgage.   Additional detail about the settlement and its implication will soon follow.

Read U.S. Department of Justice Press Release.

Read Servicing Standards

 Read Wells Fargo Press Release

Perkins Coie's Financial Services Bulletin: CFPB and FTC Issue MOU Regarding Consumer Protection Enforcement Efforts

On February 2, 2012, Perkins Coie issued its weekly Financial Services Bulletin, including an article discussing the Memorandum of Understanding between the Federal Trade Commission and the Consumer Financial Protection Bureau regarding coordinated efforts to enforce consumer protection laws.  Section 1024(c)(3) of the Dodd-Frank Act requires the CFPB and the FTC to work together to coordinate their enforcement activities and promote consistent regulatory treatment of consumer financial products and services.

Read the Perkins Coie Bulletin

Read the FTC Press Release

Read the MOU