On February 19,2020, the OCC and FDIC announced a 30-day extension of the comment period for the proposed changes for the CRA regulation. The new comment deadline will be April 8th.
TRID AND DAYLIGHT SAVING TIME
Category: CFPB, Lending Compliance, Regulation Z, TRID, Truth in Lending
Daylight Saving Time (DT) begins on Sunday March 8, 2020 at 2:00 a.m. It 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
Last month we published an article entitled Are You Libor Ready? On February 13 the Federal Reserve Bank of New York issued an Operating Policy Statement regarding publication of Secured Overnight Financing Rate (SOFR) averages and a SOFR Index to assist the transition to the new index. Publication of 30-, 90-, and 180-day SOFR Averages as well as a SOFR Index will begin March 2, 2020, in order to support a successful transition away from U.S. dollar
On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued ruling (FIN-2020-R001) on currency transaction reporting (CTR) requirements, FinCEN Form 112, involving sole proprietorships and legal entities operating under Doing Business As (DBA) names. The changes will be effective April 6, 2020, September 1 for E-Filing batch filers. This ruling replaces FIN-2006-R003 and FIN-2008-R001. For sole proprietorships the ruling states: Complete a single Part I “Person Involved in Transaction” section with the individual owner’s
2020 HMDA GUIDE
Category: CFPB, FFIEC, HMDA, Regulation C
On February 12, 2020 the Federal Financial Institutions Examination Council (FFIEC) published its 2020 version of A Guide to HMDA Reporting – Getting It Right. The Guide, which has been published since 1998, provides a summary of responsibilities and requirements, directions for assembling the necessary tools, and instructions for reporting HMDA data. The 2020 version is updated to include information from the final rule published by the CFPB in October 2019. Primarily, the 2020 Guide
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