CRIMINAL BACKGROUND CHECKS AND CREDIT REPORTS FOR LOAN ORIGINATORS
Category: CFPB, Dodd-Frank Act, Financial Reform, Lending Compliance, Regulation Z, Truth in Lending
I have had a lot of questions regarding new loan originator qualification standards that take effect on January 10, 2014. On January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published revisions to Regulation Z that expand the SAFE Act requirements that apply to Loan Originators. It is odd that SAFE Act revisions end up in the Truth in Lending Act, but this not the most seriously odd thing that Congress has done lately. Section
On March 12, 2013 the Consumer Financial Protection Bureau (CFPB) announced the availability of a preliminary list of rural and underserved counties. The final list will be available before June 1, 2013. The list has significant impact on several regulatory requirements, as follows: On June 1, 2013, the CFPB’s Escrow Requirements under the Truth in Lending Act rule (Escrows Rule) will go into effect, which require certain creditors to create escrow accounts for a minimum of 5
The appraisal rules contained in Regulation B were revised on January 18, 2013. The revisions are effective on January 18, 2014. Among other requirements, the revised regulation requires that: A copy of each appraisal or other written evaluation be provided to the applicant three business days prior to consummation; Not later than the third business day after the creditor receives the application it must provide the applicant with a notice regarding the right to receive
AVAILABILITY OF THE CHARM BOOKLET
Category: CFPB, Lending Compliance, Regulation Z, Truth in Lending
Many bankers have relied on the Federal Reserve Board (FRB) for years as an inexpensive source for the disclosure booklets required for adjustable-rate mortgages. The booklet is frequently referred to as the Consumer Handbook for Adjustable-Rate Mortgages, or CHARM Booklet. Recently it came to my attention that the CHARM Booklet is no longer available through the FRB’s website since the underlying regulation, Regulation Z, has been transferred to the Consumer Financial Protection Bureau (CFPB). However,
HUD’s EFFECTS TEST STANDARD
Category: Fair Lending, HUD
On February 15 the Department of Housing and Urban Development (HUD) published a final rule that formalizes a test for determining whether a given practice has an unjustified discriminatory effect, leading to liability under the Fair Housing Act. The final rule is effective on March 18, 2013. The regulation formalizes HUD’s long-held interpretation of the availability of “discriminatory effects” liability under the Fair Housing Act and to provide nationwide consistency in the application of that
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