On February 28, 2020, the Department of Defense (DOD) published and made effective amendments to its interpretive rule related to the Military Lending Act (MLA). The MLA, which has undergone numerous revisions over the past several years, provides protection to servicemembers and their dependents by limiting the military annual percentage rate (MAPR) that a creditor may charge to a maximum of 36 percent and requiring disclosures among other consumer protections. Revisions to the MLA regulations
On February 26, 2020 the Consumer Financial Protection Bureau expanded its list of TRID Frequently Asked Questions to include 10 questions and answers related to Lender Credits. A copy, in Word format, of the FAQs is available, for no charge, at https://mycomplianceresource.com/product/trid-faqs-on-lender-credits-2/
FDCPA – PROPOSED REVISION TO THE PROPOSED REVISION
Category: CFPB, Fair Debt Collection Practices Act, Regulation F
On February 13, 2020 the Consumer Financial Protection Bureau (CFPB) published a supplemental notice of proposed rulemaking (NPRM) dealing with the Fair Debt Collection Practices Act and Regulation F. The NPRM supplements the May 2019 Proposed Rule by proposing to require debt collectors to make certain disclosures when collecting time-barred debts. The CFPB proposes to prohibit collectors from using non-litigation means (such as calls) to collect on time-barred debt unless collectors disclose to consumers during
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
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