Washington Report 360 | March 18, 2022

Updates to CFPB’s UDAAP exam manual; Omnibus bill signed into law

Amy S. Matsuo

Amy S. Matsuo

Regulatory and ESG Insights Leader, KPMG US

+1 919-664-7100

Key Highlights

  • Fairness. CFPB announced it will “scrutinize discriminatory conduct that violates the federal prohibition against unfair practices… in all consumer finance markets, including credit, servicing, collections, consumer reporting, payments, remittances, and deposits”; companies will be expected to document processes for risk assessments/outcomes and impacts on demographic groups.
  • Cybersecurity. The Administration signed the omnibus appropriations bill, which included the Cyber Incident Report for Critical Infrastructure Act of 2022, creating requirements for entities in “critical infrastructure sectors,” including financial services, to report “covered cyber incidents” within 72 hours of recognition, or within 24 hours of ransom payments. CISA and other agencies are directed to issue associated rulemakings. (See the recent KPMG Regulatory Alert on similar SEC Cybersecurity proposals here.)

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