POINTS AND FEES – INDEX RATE FOR PERSONAL PROPERTY
Category: CFPB, Dodd-Frank Act, Financial Reform, Lending Compliance, Regulation Z, Truth in Lending
When calculating points and fees §1026.32(b)(1)(i)(E and F) allow the creditor to exclude from the calculation up to two bona fide discount points under §1026.32(b)(1)(i)(E), or up to one bona fide discount point under §1026.32(b)(1)(i)(F), paid by the consumer in connection with the transaction, if certain conditions are met. When a loan is secured by personal property, such as a mobile home, the condition is that the interest rate without any discount does not exceed
Happy New Year
Category: Uncategorized
This has been a year to remember. Unprecedented regulatory change (over 6,000 pages) have ruled the day. It appears that 2014 will also be a busy year, but we hope the pace and volume of change is more reasonable. All of us at Jack’s ComplianceResource thank you for reading Jack’s Blog this year and we look forward to serving you in 2014. We also wish a year of good health and prosperity for you and
FLURRY OF YEAR-END THRESHOLD ADJUSTMENTS
Category: CFPB, HMDA, Lending Compliance, Regulation C, Regulation Z, Truth in Lending
The Consumer Financial Protection Bureau (CFPB) just completed the usual year-end chore of updating various thresholds. The changes are based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) for various periods in 2013. Escrow Exemption for HPMLs – On December 30, 2013 the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in
HMDA – HOEPA STATUS
Category: CFPB, Dodd-Frank Act, Financial Reform, HMDA, Lending Compliance, Regulation C, Regulation Z, Truth in Lending
Section 1003.4(a)(13) of Regulation C requires that the Loan Application Register indicate, among other items, whether the loan is subject to the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 CFR 1026.32). Under current rules a loan secured by a consumer’s principal dwelling is subject to HOEPA if the loan has a high rate or high fees. Currently a loan has high fees if the total points and
It appears that the Consumer Financial Protection Bureau (CFPB) will be busy during 2014, but a lot less busy than 2013. On December 3, 2014 the CFPB published a semi-annual update to its rulemaking agenda. The fall 2013 agenda reflects both continuing work on rulemakings mandated by the Dodd-Frank Act and significant issues in other markets for consumer financial products and services. In the past year the CFPB issued rules to implement Dodd-Frank Act requirements
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.