PROPOSED HMDA CHANGES – COMMENT PERIOD EXTENDED
Category: CFPB, HMDA, Lending Compliance, Regulation C
On August 2, 2019 the Consumer Financial Protection Bureau (CFPB) extended the comment period for specific aspects of the proposed Regulation C rule published in the Federal Register on May 13, 2019 (May 2019 Proposal) from June 12, 2019 to October 15, 2019. The May 2019 Proposal proposed amendments to Regulation C relating to the coverage thresholds for reporting data on closed-end mortgage loans and open-end lines of credit and partial exemptions under the Home Mortgage Disclosure
UPDATED TRID GUIDANCE
Category: CFPB, Regulation Z, TRID, Truth in Lending
On July 31, the Consumer Financial Protection Bureau updated its TILA-RESPA Integrated Disclosure FAQs by adding five questions related to providing loan estimates to consumers: The questions include: When is a creditor required to provide a loan estimate to a consumer? Can creditors require consumers to provide additional information (other than the six pieces of information constituting an application) in order to receive a loan estimate? Can creditors require consumers to submit verifying documents before they
On July 31 the Office of the Comptroller of the Currency issued guidelines for requesting: Approval of a strategic plan (OCC Bulletin 2019-39); and Designation as a wholesale, limited purpose, or special purpose bank (OCC Bulletin 2019-40).
ONEWEST BANK REDLINING CASE
Category: Fair Housing, Fair Lending, HUD, Redlining
On July 29, 2019 the U.S. Department of Housing and Urban Development (HUD) announced that it has approved a Conciliation Agreement between the California Reinvestment Coalition and CIT Group, Inc., and CIT Bank, N.A., dba OneWest Bank, resolving allegations that the bank engaged in lending discrimination by “redlining” in the Los Angeles region. OneWest Bank is a retail bank with 60 branches in Southern California. The complaint, filed by the California Reinvestment Coalition (CRC), alleged
On July 25 the Consumer Financial Protection Bureau (CFPB) published a 30-page Advance Notice of Proposed Rulemaking (ANPR) seeking comments relating to the scheduled January 10, 2021, expiration of the temporary qualified mortgage provision applicable to loans eligible for purchase or guarantee by the Government Sponsored Enterprises, Fannie Mae and Freddie Mac. That provision is in the CFPB’s Ability to Repay/Qualified Mortgage (ATR/QM) Rule (section 1026.43 of Regulation Z). The Bureau is considering whether
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