Last week, the CFPB announced its approval of an application piloting disclosures for construction loans. In this initiative, the CFPB establishes guidelines for testing alternative disclosures in real-market scenarios, recognizing the enhanced accuracy of such tests compared to lab-based evaluations. The CFPB stated that testing in-market would allow them to gauge the potential necessity more accurately for regulatory adjustments. In short, lenders can now apply to test modified origination disclosures for construction loans to improve
On November 14, 2023, OFAC released its Guidance for the Provision of Humanitarian Assistance to the Palestinian People to “clarify that U.S. sanctions do not stand in the way of legitimate humanitarian assistance to the Palestinian people.” The Guidance reinforces existing prohibitions and authorizations, along with a brief review of applicable general licenses and Q&A. Hamas and other organizations have used NGOs to support financing of their operations, making due diligence on suspect transactions and
Despite The House of Representatives passing legislation to extend federal funding yesterday, a government shutdown still isn’t completely off the table. It still needs to make it through The Senate and be signed by President Biden. We all know a potential shutdown has far-reaching effects, but one you may not be prepared for is the lapse of the National Flood Insurance Program (NFIP). Here’s what that means for your financial institution: Your institution’s ability
Earlier this week on November 7, 2023, FinCEN issued a Final Rule on the use of FinCEN identifiers in Beneficial Ownership information reporting after commenters raised concerns that the previously proposed language could actually obscure the identities of beneficial owners. The Final Rule provides clear criteria on the use and reporting of an entity’s FinCEN identifier. What is a FinCEN identifier? A “FinCEN identifier” is a unique identifying number that FinCEN will issue to an
Don’t forget, Daylight Saving Time (DST) ends on November 5, 2023 at 2:00 a.m.! What does DST have to do with TRID, you may ask? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DST need
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