On October 3, 2016, the CFPB issued its 1,689 page Final Rule on Prepaid Accounts which was to primarily become effective on October 1, 2017. Surprisingly, the CFPB announced in a release last week, on March 9, 2017, that it was proposing to delay the implementation date for the rule until April 1, 2018. The CFPB is giving some love to the Deposit Compliance side of the bank much like it did with TRID on
Daylight Saving Time (DT) begins on March 12, 2017. What does that 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 areas that observe DT need to remember to change the time designation used
The Department of Defense (DOD) has posted a news update on its Military Lending Act (MLA) website informing users of the following: “Between February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from processing. If you submitted a Multiple Record Request file between 9 and 15 February that failed to process, please submit the file again for processing.” Under the MLA covered borrowers
On February 15, 2017, FinCEN publishes a notice in the Federal Register requesting comments on a proposed update and revision to the collection of information filed by banks in a SAR. Most of these changes would be in Part II (Suspicious Activity Information). The good news is the proposal states there are no new regulatory requirements or triggering requirements related to SARs. However, because new data fields will be added to the SAR form this likely will
CFPB SEEKS INFORMATION ON ALTERNATIVES TO TRADITIONAL CREDIT REPORTS
Category: ECOA, Fair Credit Reporting Act, Privacy
On February 16, 2017 the Consumer Financial Protection Bureau (CFPB) issued a request for information (RFI) on the potential use of alternative data and modeling techniques in the credit process. The goal of the CFPB’s inquiry is to explore options that will expand access to credit for consumers who are credit invisible or who lack enough credit history to obtain a credit score. In May 2015 the CFPB released “Data Point: Credit Invisibles” which was
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