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Last week, the FDIC provided the industry with a Financial Institution Letter (FIL 43-2015) to detail what financial institutions can expect in terms of initial examinations after the October 3rd TRID implementation date.  The first blog article in this series regarding TRID exam expectations can be found here. The Financial Institution Letter came after the CFPB released in mid-September the updated examination procedures the Bureau will rely on to complete initial exams.  In July, Director

Friday, October 2, 2015 at 4:23pm, the FDIC issued Financial Institution Letter 43-2015 which provides insight into what financial institutions can anticipate when examined by the FDIC in upcoming months. The FIL highlighted its initial supervisory expectations including: The use of the interagency examination procedures to evaluate financial institutions for compliance with the TRID rules. A copy of these procedures, which are available in the FDIC’s Compliance Examination Manual, is available here. Financial institutions may

On September 21, 2015 the Consumer Financial Protection Bureau approved a final rule amending Regulation Z. The final rule revises the CFPB’s regulatory definitions of small creditor, and rural and underserved areas, for purposes of certain special provisions and exemptions from various requirements provided to certain small creditors under the Bureau’s mortgage rules. The final rule specifically addresses: Escrow requirements for higher-priced mortgage loans; Ability-to-repay/qualified mortgage requirements; and HOEPA requirements. Small Creditor – Loan Volume

We have had several recent questions on this topic. What constitutes an application for TRID is very different from the concept of “application” for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C. It would take a large book to thoroughly explore all the nuances of “applications” under federal laws. This article explores only a few basic concepts. Regulation Z Under Section 1026.2(a)(3)(ii), for transactions subject to

We discussed the issue of the small bank exemption from the new flood insurance escrow requirements in previous articles entitled Flood Rule Conundrum and Flood Rule Conundrum – Part II. We almost called this one Flood Rule Conundrum – Part III, but we thought that would be too repetitious too repetitious. The issue is whether a small bank, that had previously escrowed for Higher-Priced Mortgage Loans (HPML), could be eligible for the new exemption from