CFPB PUBLISHES REGULATION Z ESCROW GUIDANCE
Category: CFPB, Lending Compliance, Regulation Z, Truth in Lending
On April 19th the Consumer Financial Protection Bureau (CFPB) published TILA Escrow Rule Small Entity Compliance Guide. The 21- page Guide provides a summary of the TILA Escrow Rule. The guide also highlights issues that small creditors might find helpful to consider when implementing the rule. The Guide is available here.
REVISED HMDA GUIDE
Category: FFIEC, HMDA, Lending Compliance, Regulation C
On April 18th the Federal Financial Institutions Examination Council (FFIEC) published an updated version of A Guide to HMDA Reporting: Getting It Right. This is the first time the Guide has been updated since 2010. The 2013 edition reflects the transfer of authority over Regulation C from the Federal Reserve Board to the Consumer Financial Protection Bureau. Appendix D, comment 1003.2 is updated with the asset-size threshold exemption applicable to collection of 2013 data. There
PROPOSED REVISION TO 2013 FINAL ESCROW RULE
Category: CFPB, Dodd-Frank Act, Lending Compliance, Regulation Z, Truth in Lending
On April 11, 2013 the Consumer Financial Protection Bureau (CFPB) proposed revisions to the final rule it adopted in January 2013. The proposal clarifies the determination method for the “rural” and “underserved” designations and keeps in place certain existing protections for HPMLs until other similar provisions take effect in January 2014. The January rule can be read to cut off certain existing consumer protections before the new expanded protections take effect. The confusion arose because
CFPB ABILITY TO REPAY AND QM GUIDANCE
Category: CFPB, Lending Compliance, Regulation Z, Truth in Lending
On April 10, 2013 the Consumer Financial Protection Bureau published two compliance tools to assist financial institutions with implementation of the ability to repay and the qualified mortgage rules. The first tool is a 45-page booklet entitled Ability-to-Repay and Qualified Mortgage Rule – Small Entity Compliance Guide. The Guide is available here. The second tool is a 1½ page chart entitled General Comparison of Ability-to-Repay Requirements with Qualified Mortgages. The chart is available here.
REGULATION E AMENDMENT ELIMINATES ATM NOTICE
Category: CFPB, Electronic Fund Transfer Act, Regulation E
Recently the Bureau of Consumer Financial Protection amended Regulation E, which implements the Electronic Fund Transfer Act (EFTA), and the official interpretation to the regulation. In December 2012, Congress passed and the President signed legislation amending the EFTA to eliminate a requirement that a fee notice be posted on or at automated teller machines, leaving in place the requirement for a specific fee disclosure to appear on the screen of that machine or on paper
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