CFPB FAQS FOR OPEN-END CREDIT AND COVID-19
Category: CFPB, Coronavirus, Regulation Z, Truth in Lending
On May 13 the Consumer Financial Protection Bureau (CFPB) published three Frequently Asked Questions (FAQs) regarding open-end (not home-secured) rules related to the COVID-19 pandemic. The FAQs are “compliance aids,” which do not have the weight of the law or the regulations. The first FAQ addresses changes to account terms. The answer indicates that a creditor may change terms on an open-end account, although most significant changes in terms require advance notice. It clarifies that
CFPB STATEMENT ON REGULATION Z BILLING ERRORS – CLARIFICATION OR ADDED CONFUSION
Category: CFPB, Regulation Z, Truth in Lending
On May 13 the Consumer Financial Protection Bureau (CFPB) published a Statement on Supervisory and Enforcement Practices Regarding Regulation Z Billing Error Resolution Timeframes in Light of the COVID-19 Pandemic (the statement). The Truth in Lending Act generally requires that creditors investigate and resolve consumers’ billing error notices within specified maximum timeframes. Good news – The statement provides notice to creditors that the CFPB intends to take a flexible supervisory and enforcement approach with respect
FLOOD INSURANCE COMPLIANCE IN RESPONSE TO THE CORONAVIRUS
Category: Coronavirus, Federal Reserve Board, Flood Insurance
On May 6, 2020 the Federal Reserve Board issued Consumer Affairs letter CA 20-7 on the topic of Flood Insurance Compliance in Response to the Coronavirus. On March 9, the Federal Reserve Board and the other federal financial institution regulatory agencies and state bank regulators issued a statement to encourage financial institutions to meet the financial services needs of their customers and members in areas affected by the coronavirus.Since that time, the Federal Reserve Board
REGULATION B – CLARIFICATION FOR PPP LOANS
Category: CFPB, Coronavirus, ECOA, PPP Loans, Regulation B
On May 6 the Consumer Financial Protection Bureau (CFPB) issued three clarifying Frequently Asked Questions ( FAQs) to support small businesses who have applied for a loan from their financial institution under the Small Business Administration’s (SBA) Paycheck Protection Program (PPP). Question 1. – Creditors are generally required under the Equal Credit Opportunity Act and Regulation B to notify applicants within 30 days of receiving a “completed application” of the creditor’s approval, counteroffer, denial or
IRS ISSUES Q&AS ON CORONAVIRUS-RELATED RELIEF FOR IRAs AND RETIREMENT PLANS
Category: Deposit Compliance
Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, special rules were implemented to provide relief to Americans impacted by the pandemic. This relief includes providing easier access to retirement and IRA funds for those who need it through special distribution options and rollover rules, as well as permissible loans from certain retirement plans. The 14 Q&As released by the IRS addresses questions by both individuals and administrators related to the relief for retirement
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