Should the Consumer Financial Protection Bureau issue guidance? Or should it reject guidance and stick with notice-and-comment rulemaking under the Administrative Procedures Act? That’s the question following the use of the Congressional Review Act (CRA) to repeal the bureau’s 2013 bulletin providing guidance on indirect auto lending.
Congress has acted to repeal guidance, and the bureau has said it will review more that might be subject to CRA. But the new reform bill specifically asks the CFPB to issue guidance on TRID.
What’s an agency to do? What guidance could be subject to CRA and immediately impact RESPA compliance? Read on for more.
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