On July 21 the Department of Defense (DOD) published a final rule revising Part 232, which implements the Military Lending Act (MLA). The new rules will impact most lenders. The Military Lending Act became law in 2006. Part 232 was effective on October 1, 2007. While the MLA appeared to apply very broadly, Part 232 severely restricted coverage. Most lenders have not paid much attention to the existing regulations due to limits on the types […]
Month: July 2015
FLOOD RULE CONUNDRUM: DOES YOUR FINANCIAL INSTITUTION QUALIFY FOR THE SMALL LENDER EXCEPTION?
On June 22nd, the agencies (FRB, OCC, FDIC, NCUA, and FCA) issued a joint final rule to modify existing flood regulations. On June 24th, we issued an article discussing these new interagency flood rules (to access that article click here) that examined the three main elements of the final rule: detached structures, escrow provisions, and force placement. Since then we have received numerous questions relating to the small lender exception to the escrow portion of […]
FOOT-DRAGGING
Can’t get excited about the CFPB’s fourth birthday? Well let’s celebrate the continued foot-dragging on the part of the CFPB and other Federal agencies. Section 1071 of the Dodd-Frank Act amended the Equal Credit Opportunity Act to require financial institutions to collect and report information concerning credit applications made by women- or minority-owned businesses and by small businesses. The law established an effective date of July 21, 2011. Since Section 1071 was scheduled to be […]
CFPB FINALIZES TRID DELAY
On Tuesday the Consumer Financial Protection Bureau (CFPB) issued a final rule extending the effective date of the Truth-in-Lending Act/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) rule to October 3, 2015. The original effective date was set for August 1, 2015. On June 24, 2015, the Bureau proposed a two month extension of the effective date to correct an administrative error that would have delayed the effective date of the rule by at least […]
HAPPY ANNIVERSARY!
Today is the fifth anniversary of the Dodd-Frank Act and it’s the CFPB’s fourth birthday. Do you feel like celebrating? The Dodd-Frank Act continues to stir up controversy and is likely to be a topic of much discussion during the upcoming presidential campaigns. By one estimate only 60% of the total Dodd-Frank rules have been completed; the rest will continue to unfold in the coming years. The Dodd-Frank Act spawned the Consumer Financial Protection Bureau. […]