FLOOD RULE CONUNDRUM PART II: CONSENSUS AMONG AGENCIES ON SMALL LENDER EXCEPTION
Category: Biggert-Waters, Flood Insurance
It has been over seven weeks since the Agencies (FRB, OCC, FDIC, NCUA, and FCA) issued a joint final rule to modify existing flood regulations. And until this week the Agencies had inconsistent opinions about how the small lender escrow exception will apply to lenders that were required to escrow under Regulation Z’s Higher Priced Mortgage Loan (HPML) rules. This week we learned some good news – it appears we now have a consensus among
TRID DISCLOSURE FOR PREFERRED-RATE LOANS
Category: CFPB, Integrated Disclosures, Lending Compliance, Regulation Z, Truth in Lending
Typical preferred-rate loans might include a fixed-rate mortgage loan that carries a preferred rate as long as the borrower remains an employee of the financial institution or as long as a deposit account remains open. This loan type raises several issues under TRID rules including, which product description should be used. The product description, explained in §1026.37, must classify the rate as “Adjustable Rate,” “Step Rate,” or “Fixed Rate.” For an “Adjustable Rate” the rates
I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real
NEW MILITARY LENDING ACT REGULATIONS
Category: Department of Defense, Military Lending Act, Part 232
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
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
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