The one provision of the Dodd-Frank Act that strikes fear in the heart of bankers is the requirement to collect and report HMDA-like information on business loans. The provision is supposed to be effective on July 21, 2011. But since we don’t even have proposed regulations yet, we have suspected for some time now that the provision will be delayed. Leonard Kennedy, the recently appointed General Counsel of the Consumer Financial Protection Bureau, has made […]
Month: April 2011
WHAT’S UP WITH FORECLOSURES
Foreclosures are getting a lot of attention right now. In early February the news was that foreclosure-related documents were being signed and processed without being read. On April 13, 2011 the federal bank regulatory agencies took enforcement action against 14 financial institutions for engaging in a pattern of misconduct and negligence related to foreclosures. There are also rumblings of fair lending problems related to foreclosures. So why is the spotlight on foreclosures? It is a […]
THE YEAR OF UNCERTAINTY
We are living in the time of the most overwhelming change to lending compliance rules and to the structure of the regulatory agencies that enforce the rules since civil rights and consumer protection rules were first written in the late 1960s. We hope the picture will soon develop enough so we can discern the future of compliance. While the Fed has already begun to wind down it’s regulation writing activities, as evidenced by shelving the […]
WHAT’S UP WITH REGULATION Z COMPENSATION RULES
Regulation Z loan origination compensation rules were slated to become mandatory for applications received on or after April 1, 2010. The rules apply to closed-end consumer credit transactions secured by a dwelling. Two entities, the National Association of Mortgage Brokers (NAMB) and National Association of Independent Housing Professionals, Inc. (NAIHP), sought to prevent enforcement of the loan originator rules, asserting the Federal Reserve Board exceeded its authority in promulgating them. On March 30, 2011, the […]
NEW FDIC ADDRESS
On March 25 the FDIC issued FIL 18-2011 announcing a change in the address of its Consumer Response Center. The change was effective March 28. * This change is applicable only to FDIC-supervised institutions. Federally chartered banks, credit unions, and other institutions supervised by another federal bank regulatory agency are not affected by this change of address. * FDIC regulated banks need to change the address that appears on their adverse action notices. Generally this […]