On August 22, 2014, the Consumer Financial Protection Bureau (CFPB), Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), and Office of the Comptroller of the Currency (OCC) (herein “Agencies”) issued the above referenced Interagency Guidance (click here). While we recommend that you read the Guidance, a redacted version is reprinted below: The credit practices rules for banks, savings associations, and Federal credit unions are being repealed as a consequence of the Dodd-Frank Act. Notwithstanding the repeal of these regulations, the Agencies have supervisory and enforcement authority regarding unfair or deceptive acts or practices, which could include the practices previously addressed in the former credit practices rules.

Complete Memorandum