PENDING LENDING ISSUES
Category: CFPB, FDIC, Federal Reserve Board, Flood Insurance, Lending Compliance, OCC, Regulation Z
Can we see the light at the end of the tunnel? Maybe faintly. Truth-in-Lending/RESPA Integrated Disclosures (TRID) – The biggest pending issue is the TRID rules that are effective August 1, 2015. Some vendors have delivered updates to loan origination software for testing. Policies, procedures, and training need to be completed. But it is appears likely that most lending institutions will complete all required tasks by the deadline. Some, like the banker I talked to
2015 HMDA ISSUES
Category: FFIEC, HMDA, Regulation C
The January 2015 issue of the FFIEC’s CRA/HMDA Reporter has several good reminders about HMDA issues. The lead article, HOEPA Changes and New Edit Changes, focuses on changes to Regulation Z (HOEPA) rules that were effective in January 2014 and impacted the 2014 HMDA data just submitted by your bank. The changes lowered the rate spread threshold of HOEPA eligible loans, and expanded coverage to certain home purchase mortgage products. The Reporter is available by
As we originally reported in Spring 2014 the Supreme Court of the United States (SCOTUS) granted review in the case of Jesinoski v. Countrywide Home Loans. In the case, argued on November 4, 2014, and decided January 13, 2015, SCOTUS reversed and remanded the decision of the Eighth Circuit Court of Appeals. In a unanimous opinion delivered by Justice Scalia, the court held that a “borrower exercising his right to rescind under the Act need only provide written
CFPB PROPOSAL IMPACTS SMALL CREDITORS AND RURAL AND UNDERSERVED AREAS
Category: CFPB, Lending Compliance, Regulation Z, Truth in Lending
On January 29, 2015 the Consumer Financial Protection Bureau (CFPB) proposed several changes to Regulation Z that impact small creditors, particularly in rural and underserved areas. The proposal would increase the number of financial institutions able to offer certain types of Qualified Mortgages (QM) in rural and underserved areas. Ability -to-Repay rules, which took effect in January 2014, require lenders to make a reasonable and good-faith determination that prospective borrowers have the ability to repay
FINAL RULE REVISES TIL AND RESPA
Category: CFPB, Lending Compliance, Regulation X, Regulation Z, RESPA, Truth in Lending
On January 18, 2015 the Consumer Financial Protection Bureau (CFPB) approved final changes to Regulations X and Z. The changes are effective on August 1, 2015. The final rule: Extends the timing requirement for revised disclosures when consumers lock a rate or extend a rate lock after the Loan Estimate is provided; Clarifies placement of the Nationwide Mortgage Licensing System and Registry ID (NMLSR ID) on the integrated disclosures; Permits certain language related to construction
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