45-DAY LOOK BACK PERIOD FOR ARMs – ARE YOU SET?
Category: Lending Compliance, Regulation Z, Truth in Lending
Effective on January 10, 2014 Section 1026.20 of Regulation Z requires, when a rate change accompanied by a payment change occurs on an ARM, a notice to be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due. However a different timing rule (at least 25, but no more than 120, days before the first payment at the adjusted level is due) applies
PROPOSED DEFINITION OF DELINQUENCY
Category: CFPB, Lending Compliance, Regulation X, Regulation Z, RESPA, Truth in Lending
On November 19, 2014 the Consumer Financial Protection Bureau (CFPB) published proposed changes to Regulations X (RESPA) and Z (TIL). Among other items the proposal contains extensive comment on the definition of the term “delinquency” when used for determining when the first notice regarding foreclosure under section 1024.41(f)(1)(i) may be sent. Section 1024.31 contains definitions for various terms that are used throughout the provisions of subpart C of Regulation X. It does not contain a
PROPOSED CHANGES TO REGULATIONS X AND Z
Category: CFPB, Lending Compliance, Regulation X, Regulation Z, RESPA, Truth in Lending
Earlier this week the Consumer Financial Protection Bureau published proposed changes to Regulations X (RESPA) and Z (TIL). The proposed changes focus primarily on clarifying, revising, or amending provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and periodic statement requirements under Regulation Z’s servicing provisions. Extensive proposed comment appears on the definition of the term “delinquency” when used, among other purposes, for determining when
Earlier this week the Consumer Financial Protection Bureau (CFPB) published a article and issued a bulletin on the topic of Social Security disability income. In our November 10th article on the same topic we warned you of the discrimination risk involved in verifying this type of income. Now you can hear the same message from the CFPB. In the past, Social Security disability income recipients have faced special challenges in providing proof that their disability
Recently the U.S. Department of Housing and Urban Development (HUD) announced that it has entered into an Initial Decision and Consent Order with American Bank, resolving HUD’s charge that the Rockville, Maryland-based lender discriminated against applicants with disabilities when it allegedly required applicants to provide documentation regarding their disabilities and attempted to obtain information about the nature and extent of those disabilities. Cases similar to this are being common. HUD charged the lender with unlawful
Why we blog . . .
The ever-changing laws, regulations, proposals, deadlines, and guidance are a lot for anyone to manage and keep up with so let us do the work for you. Our blog is designed to help compliance professionals by releasing updates as soon as the news breaks. Our Compliance Resource team is researching, following, and monitoring government agencies and regulators to give you all the latest and greatest compliance news. Our goal is to work harder so you don’t have to.