On June 22 the Consumer Financial Protection Bureau (CFPB) issued two separate proposals to revise the Ability to Repay/Qualified Mortgages rules contained in Section.1026.43 of Regulation Z The first proposal is 233 pages in length. For General QM loans, the ratio of the consumer’s total monthly debt to total monthly income (DTI ratio) must not exceed 43 percent. The CFPB proposes certain amendments to the General QM loan definition in Regulation Z. Among other things,
SCOTUS SEXUAL ORIENTATION DECISION
Category: CFPB, ECOA, Fair Housing, Regulation B, SCOTUS
On June 15, 2020 the U.S. Supreme Court (SCOTUS), in Bostock v Clayton County, Georgia (Bostock) ruled that firing an employee for being homosexual or transgender constitutes discrimination based on the employee’s sex in violation of Title VII of the Civil Rights Act. Bostock is an employment case in which SCOTUS determined that disparate treatment of homosexual or transgender individuals is sex discrimination. Both the Equal Credit Opportunity Act (ECOA) and the Fair Housing Act
On June 12 the Small Business Administration published an interim final rule (IFR) to update its April 2 IFR on the Paycheck Protection Program (PPP). On June 5, 2020, the Paycheck Protection Program Flexibility Act of 2020 (Flexibility Act) was signed into law, amending the CARES Act. This interim final rule changes key provisions, such as the loan maturity, deferral of loan payments, and forgiveness provisions, to conform to the Flexibility Act. SBA also is
PROPOSED REGULATION Z CHANGES FOR LIBOR TRANSITION
Category: CFPB, LIBOR, Regulation Z, Truth in Lending, Uncategorized
On June 4, 2020 the Consumer Financial Protection Bureau (CFPB) published a 219 page proposal to amend Regulation Z to facilitate creditors’ transition away from using the London Interbank Offered Rate (LIBOR) as an index for variable-rate consumer credit products. The CFPB is proposing changes to: Certain open-end and closed-end provisions to provide examples of replacement indices for LIBOR indices that meet certain Regulation Z standards. Certain open-end provisions restricting index changes, requiring change-in-terms notices,
On June 9 the Consumer Financial Protection Bureau (CFPB) published a nine-page booklet entitled Factsheet: TRID Title Insurance Disclosures. The factsheet clarifies the disclosures for both Lender and Owner’s Title Insurance, including the disclosure of a simultaneous issuance. Several helpful examples are included. On June 9 the CFPB also published three new Frequently Asked Questions (FAQs). The new FAQs explain: Seller-Paid Loan Costs and Other Costs on Separate Closing Disclosures to the Seller and the
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