Archive

CFPB FACTSHEET – APR CALCULATION FOR GENERAL QM

On February 23, 2022, the Consumer Financial Protection Bureau (CFPB) published Factsheet: Prepaid Interest and the General Qualified Mortgage APR Special Rule for Adjustable Rate Mortgages. Creditors that wish to make qualified mortgages (QMs) under the price-based General QM definition must calculate the annual percentage rate (APR) for loans to determine whether they satisfy the price-based General QM definition. The priced-based General QM definition contains a special rule for calculating the APR for loans where […]

OCC PUBLISHES FAQS ON RESCINDED CRA RULE

On February 22, 2022, the Comptroller of the Currency (OCC) issued OCC Bulletin 2022-4 that provides responses to frequently asked questions (FAQ) about the December 2021 final rule to rescind the OCC’s Community Reinvestment Act (CRA) rule issued on June 5, 2020 (June 2020 CRA rule). The December 2021 CRA final rule, effective January 1, 2022, replaced the June 2020 CRA rule with provisions largely based on the rules adopted jointly by the OCC, the Board of […]

INTERAGENCY STATEMENT ON SPECIAL PURPOSE CREDIT PROGRAMS

On February 22, 2022, The Board of Governors of the Federal Reserve System (FRB), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC), the Consumer Financial Protection Bureau (CFPB or Bureau), the Department of Housing and Urban Development (HUD), the Department of Justice (DOJ), and the Federal Housing Finance Agency (hereafter, the agencies) issued an interagency statement to remind creditors of the ability […]

TRID AND DAYLIGHT SAVING TIME

Daylight Saving Time (DST) begins on Sunday March 13, 2022 at 2:00 a.m. It ends on November 6, 2022 at 2:00 a.m. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in […]

NATIONAL FLOOD INSURANCE PROGRAM CONTINUED

On February 17, 2022, the Senate approved a stopgap bill to avert a shutdown at the end of the week ahead of a looming Friday deadline when government funding has been set to expire. The House of Representatives voted last week on a bipartisan basis to approve the measure, known as a continuing resolution, to extend funding through March 11. Now that the Senate has passed the measure it can be sent to President Joe Biden’s desk […]