REGULATION B AND THE NEW UNIFORM RESIDENTIAL LOAN APPLICATION
Category: CFPB, ECOA, HMDA, Regulation B, Regulation C
On September 23 the Consumer Financial Protection Bureau (CFPB) published an Official Approval concerning the new Uniform Residential Loan Application and the collection of expanded Home Mortgage Disclosure Act information about ethnicity and race in 2017. The official approval was issued on September 23, 2016. Entities may rely on the official approval beginning January 1, 2017. The official approval is issued separately from, and without amending, the official interpretations to Regulation B contained in Supplement
COUNTDOWN TO THE MILITARY LENDING ACT
Category: Department of Defense, Military Lending Act, Part 232
In one week, on October 3, 2016, compliance with the revisions to Part 232, which implements the Military Lending Act (MLA), is mandatory. The revised rules were effective on October 1, 2015. but the revised provisions do not apply to credit consummated before October 3, 2016. For any covered transaction consummated on or after October 3, 2016 the creditor must provide required disclosures, assure the Military Annual Percentage Rate does not exceed 36%, and abide
Why Comply With 2018 CDD Requirement Now
Category: Beneficial Ownership, BSA, Consent Decree, FinCEN
The OCC entered into a Consent Decree with Business Bank of Texas on July 20, 2016 after the OCC initially announced its intentions to issue a Cease and Desist (C&D) Order. Previously, we issued a blog on the Beneficial Ownership FAQs (posted August 18, 2016) which stated that May 11, 2018 was the applicability date for the following requirements: Identification and Verification of Legal Entity Customers; and Requirement to add a new “fifth pillar”: Understand
REGULATION E ERROR RESOLUTION AND POLICE REPORTS – NEITHER THE TWAIN SHALL MEET?
Category: CFPB, Electronic Fund Transfer Act, Regulation E, UDAAP
During a recent Regulation E training event, the class and I discussed the Regulation E Section 1005.11 “Procedures for resolving errors” and there, as always, was very active discussion of what a bank may request, but not require. I brought up the prohibition against requiring police reports as a requirement for the bank to either begin the investigation provision or to provide provisional credit and there were a number of questions. Many banks have in
On August 26 the Department of Defense (DOD) published 19 questions and answers concerning the requirements of the Military Lending Act and its Part 232. Many questions have swirled around the provisions of Part 232 for some now. Some of the questions are clearly answered in the document; other answers are quite fuzzy. The questions and answers represent official interpretations of the DOD on issues related to 32 CFR part 232. The interpretations are effective
Why we blog . . .
The ever-changing laws, regulations, proposals, deadlines, and guidance are a lot for anyone to manage and keep up with so let us do the work for you. Our blog is designed to help compliance professionals by releasing updates as soon as the news breaks. Our Compliance Resource team is researching, following, and monitoring government agencies and regulators to give you all the latest and greatest compliance news. Our goal is to work harder so you don’t have to.