DISCRIMINATION AGAINST NATIVE AMERICANS
Category: Fair Housing, Fair Lending, HUD, Lending Compliance
Are we in a time warp? Are we back in the 80’s? On September 15, 2014 the Department of Housing and Urban Development (HUD) announced a settlement agreement with U.S. Bank National Association, U.S. Bank subsidiary Red Sky Risk Services, LLC (formerly known as USB Lending Support Services, LLC), and one of U.S. Bank’s loan officers, resolving allegations that they refused to refinance the mortgage of a Native American couple in Belcourt, North Dakota, because
INTERAGENCY GUIDANCE ON HELOCS NEARING THEIR END-OF-DRAW PERIODS
Category: FDIC, Federal Reserve Board, HELOC, Lending Compliance, OCC, Regulation Z
On July 1, 2014 the federal financial institution regulatory agencies published guidance regarding the risk associated with Home Equity Lines of Credit (HELOCs) transitioning from their draw periods to full repayment. This is not a new issue. HELOCs have been part of product mix for financial institutions since the 1980s. Most HELOCs have a five or ten year draw period. During the draw period, a borrower has revolving access to unused amounts under a specified
PROPOSED REPEAL OF REGULATION AA
Category: CFPB, Dodd-Frank Act, FDIC, Federal Reserve Board, OCC, UDAAP
On August 22, 2014 the Federal Reserve Board requested comment on a proposal to repeal its Regulation AA (Unfair or Deceptive Acts or Practices). Also on Friday, the Board, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency issued guidance clarifying that the repeal of the credit practices rules applicable to banks, savings associations, and federal credit unions is not a determination that the
Last month, on the occasion of its third anniversary, the Consumer Financial Protection Bureau (CFPB) touted its numerous successes in its three years of existence, including $4.6 billion in relief and refunds for consumers. That number will take a big jump when the CFPB adds in its recent $16.65 billion settlement with Bank of America. A $16.65 billion settlement is big number by any measurement. But subsequently it has been reported that B of A
Have your customers been asking about virtual currencies, such as Bitcoin? Do you have answers for their questions? Occasionally the Consumer Financial Protection Bureau (CFPB) lives up to their name. Recently the CFPB published a very helpful Consumer Advisory entitled Risks to Consumers Posed by Virtual Currencies. The Advisory explains how virtual currencies work and various risks associated with the product. It includes several real world stories of losses resulting from fraud and mishandling of virtual currencies.
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