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We are living in the time of the most overwhelming change to lending compliance rules and to the structure of the regulatory agencies that enforce the rules since civil rights and consumer protection rules were first written in the late 1960s. We hope the picture will soon develop enough so we can discern the future of compliance. While the Fed has already begun to wind down it’s regulation writing activities, as evidenced by shelving the

Regulation Z loan origination compensation rules were slated to become mandatory for applications received on or after April 1, 2010. The rules apply to closed-end consumer credit transactions secured by a dwelling. Two entities, the National Association of Mortgage Brokers (NAMB) and National Association of Independent Housing Professionals, Inc. (NAIHP), sought to prevent enforcement of the loan originator rules, asserting the Federal Reserve Board exceeded its authority in promulgating them. On March 30, 2011, the

On March 25 the FDIC issued FIL 18-2011 announcing a change in the address of its Consumer Response Center. The change was effective March 28. * This change is applicable only to FDIC-supervised institutions. Federally chartered banks, credit unions, and other institutions supervised by another federal bank regulatory agency are not affected by this change of address. * FDIC regulated banks need to change the address that appears on their adverse action notices. Generally this

On March 25th the Federal Reserve Board adopted a new rule that expands the coverage of Regulation Z to credit transactions of higher dollar amounts. The final rule amends Regulation Z to implement a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Effective July 21, 2011, the Dodd-Frank Act requires that the protections of the Truth in Lending Act (TILA) apply to consumer credit transactions up to $50,000, compared with $25,000 currently.

On March 18th the Federal Reserve Board approved a rule amending Regulation Z (Truth in Lending) to clarify prior rules implementing the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Credit Card Act). The rule enhances protections for consumers who use credit cards and resolves areas of uncertainty so that card issuers fully understand their compliance obligations. The Credit Card Act requires that, before opening a new credit card account or increasing the credit