On November 6, 2020, the Comptroller of the Currency, the Federal Reserve Board and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a Statement on Reference Rates for Loans. The statement reiterates that the agencies are not endorsing a specific replacement rate for LIBOR for loans. A bank may use any reference rate for its loans that the bank determines to be appropriate for its funding model and customer needs. However, the bank should
CFPB PUBLISHES FINAL DEBT COLLECTION PRACTICES ACT RULE
Category: CFPB, Fair Debt Collection Practices Act, Regulation F
On October 30, 2020. the Consumer Financial Protection Bureau (CFPB) issued a final Regulation F, which governs the activities of debt collectors. The final rule addresses, among other things, communications in connection with debt collection and prohibitions on harassment or abuse, false or misleading representations, and unfair practices in debt collection. The final rule: Will be effective one year after publication in the Federal Register, which is expected soon. Together with the supplementary information, runs
On October 26, 2020, the Consumer Financial Protection Bureau (CFPB) issued a consent order against Low VA Rates LLC (Low VA Rates) to address the CFPB’s finding that Low VA Rates sent consumers mailers for mortgage loans guaranteed by the U.S. Department of Veterans Affairs (VA) that contained false, misleading, and inaccurate statements. Low VA Rates’ conduct violated the Consumer Financial Protection Act’s (CFPA) prohibition against deceptive acts and practices, the Mortgage Acts and Practices
It’s that time of year again…the Nationwide Multistate Licensing System and Registry’s (NMLS) renewal period for 2021 begins November 1 and continues through December 31, 2020. All Mortgage Loan Originators (MLO), as defined in Regulation G, 12 CFR 1007, who are registered with the Registry are required to complete the annual registration renewal. One exception to the renewal requirement is for MLOs who completed their initial registration with the Registry less than six months prior
Daylight Saving Time (DT) ends on November 1, 2020 at 2:00 a.m. What does DT have to do with TRID? 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 DT need to remember to change the
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