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The Gramm-Leach-Bliley Act (GLBA) requirement to provide an annual privacy notice has been amended by Title LXXV of the Fixing America’s Surface Transportation Act or the FAST Act of 2015 (Public Law 114-94), enacted on December 4, 2015. The FAST Act amends Section 503 of the GLBA to create an exception to the annual privacy notice requirement for financial institutions that: Do not share nonpublic personal information in any way that requires an opt-in under

This week the Consumer Financial Protection Bureau (CFPB) issued its Rural and Underserved Areas Tool linked here https://www.consumerfinance.gov/rural-or-underserved-tool/. The tool is designed to assist creditors in determining if properties are located in a rural or underserved area and eligible for certain exemptions from various requirements provided to certain small creditors under the CFPB’s mortgage rules. The Rural and Underserved Areas Tool is a the result of a final rule approved by the CFPB on September

Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements

Two innocent looking disclosures, but who knows the evil that lurks within. Loan Estimate: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses on your home. If you lose this protection, you may have to pay any debt remaining even after foreclosure. You may want to consult a lawyer for more information. Regulation: Section 1026.37(m)(7) requires the Loan Estimate

In remarks at the recent Mortgage Bankers Association Convention Consumer Financial Protection Bureau Director Richard Cordray conceded that the implementation process for CFPB’s new “Know Before You Owe” mortgage disclosure rule (aka as TRID) has not been as smooth as the agency would have hoped. But Cordray faulted vendors, not regulators. “Quite frankly, I have been disturbed by reports I have been hearing about the vendors on whom so many of you rely,” he said.