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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

Recently shares in a South Carolina lending business plummeted after the company disclosed it might face legal action from the Consumer Financial Protection Bureau (CFPB). Shares of World Acceptance Corporation (World), a Greenville-based company, dropped by almost $19, or 36 percent per share, to about $33. The company disclosed last year that it received a “civil investigative demand” from the CFPB. At that time, the agency said it was trying to determine whether the lender

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

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