CFPB PRIVACY PROPOSAL PROMOTES MORE EFFECTIVE DISCLOSURES: GOOD NEWS
Category: CFPB, Privacy, Regulation P
On May 6, 2014, the Consumer Financial Protection Bureau (CFPB) proposed a rule that would amend Regulation P, Privacy of Consumer Financial Information. The proposed rule would promote more effective privacy disclosures from financial institutions to their customers, while also providing some good news for banks. Currently financial institutions send annual privacy notices to their customers that describe if and how consumer’s nonpublic personal information will be shared. If the institution shares information with an
As explained in the first part of this article implementing the new integrated disclosures is a massive task. Lenders that have a plan and get an early start on the process will complete the task by the August 1, 2015 deadline with minimal stress to all involved. We advocate a three-step process for implementing the New disclosures. Master the Material – Mastering 1,888 pages of regulation and related material doesn’t happen quickly. Most of us
The Consumer Financial Protection Bureau (CFPB) published final rules to implement the new integrated disclosures on November 20, 2013. The rules complete the Dodd-Frank mandate to combine the disclosures required by the Truth-in-Lending (TILA) and Real Estate Settlement Procedure Acts (RESPA). The regulations, the Official Interpretations and instructions for completing the forms are massive, covering 1,888 pages. Have you begun the implementation process yet? You have until August 1, 2015 to complete the task,
On April 30 the Consumer Financial Protection Bureau (CFPB) proposed changes to Regulation Z rules related to the small servicer exemption and to the qualified mortgage rules. The proposal is on a fast track, with a 30-day comment period. Small Servicer The proposed changes to the small servicer rules are nice. The CFPB proposes an alternative small servicer definition for nonprofit entities that meet certain requirements, and amend the existing exemption from the ability-to-repay rule
RESCISSION CASE HEADED TO SUPREME COURT
Category: Lending Compliance, Regulation Z, Truth in Lending
As we reported on March 21 (click here for article) the federal appeals courts are divided on whether a borrower timely exercises the right of rescission by sending the creditor a rescission notice within three years of consummation or whether the borrower must also file a lawsuit within three years. The U. S. Supreme Court has granted review in one of the rescission cases we reported. The case (Jesinoski v. Countrywide Home Loans) will be
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