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PROPOSED REG Z REVISION – CREDIT CARD FEE LIMIT

Posted by jholzknecht on  April 14, 2012
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Issue – The Bureau of Consumer Financial Protection (Bureau) is proposing to amend Regulation Z. Regulation Z generally limits the total amount of fees that a credit card issuer may require a consumer to pay with respect to an account, limiting fees to 25 percent of the credit limit in effect when the account is opened. Regulation Z currently states that this limitation applies prior to account opening and during the first year after account

RENEWING LOANS WITH FORCE PLACED INSURANCE

Posted by jholzknecht on  April 11, 2012
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“Can we renew a loan which is covered by force placed insurance?” Variations on this question have come up several times in recent seminars I have conducted. The answer to the question is no. If a borrower refuses to obtain flood insurance coverage as a condition of obtaining a loan, the loan is deficient and may not be made. Force placement of coverage is designed for use at any time during the loan in uninsured

SMALL BANK REGULATORY RELIEF?

Posted by jholzknecht on  April 6, 2012
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Category: Financial Reform
Last month all of the federal financial institution regulatory agencies showed up at Independent Community Bankers of America’s national convention and told those in attendance what they wanted to hear. “The future of community banking is a major priority.” “We have undertaken a review of the history of community banking.” And my favorite, “Where it makes sense to treat community banks differently from larger institutions, we have pledged to consider doing so.” Not a single

THREE-YEAR RIGHT TO RESCIND

Posted by jholzknecht on  April 6, 2012
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Over the years many of you have heard me discuss the rescission rules contained in Regulation Z. I always explained that if the lender screws up and fails to give the notice, fails to give a timely notice, fails to give the correct notice, fails to properly complete the notice, fails to wait three days before distributing the form, fails to give timely and accurate TIL disclosures, or makes any one of several other errors

NEW FEDERAL REGISTRY RESOURCE CENTER OPENS

Posted by jholzknecht on  April 3, 2012
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On April 2, 2012 the Nationwide Mortgage Licensing System & Registry opened a new Federal Registry Resource Center. Everything needed for Federal Registration is available in the new center, including all Quick Guides, instructions and reference materials that pertain to Federal Registration. The new Center is available at: https://fedregistry.nationwidelicensingsystem.org/Pages/default.aspx
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