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On March 18, 2019 the Federal Deposit Insurance Corporation (FDIC) issued a final rule rescinding its regulations at 12 CFR 350, entitled Disclosure of Financial and Other Information By FDIC-Insured State Nonmember Banks. Upon the effective date, all insured state nonmember banks and insured state licensed branches of foreign banks will no longer be subject to the annual disclosure statement requirements set out in the existing regulations at 12 CFR 350. The annual disclosure under

On May 24, 2018 the Economic Growth, Regulatory Relief, and Consumer Protection Act was signed into law. Among its many provisions Section 307 amends the Truth in Lending Act (TILA) to mandate that the Consumer Financial Protection Bureau (CFPB) prescribe certain regulations relating to residential Property Assessed Clean Energy (PACE) financing. Specifically, the regulations must carry out the purposes of TILA’s ability-to-repay (ATR) requirements, currently in place for residential mortgage loans, with respect to PACE

Daylight Saving Time (DT) begins on March 10, 2019 at 2:00 a.m. It ends on November 3, 2019 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 areas

On February 27, 2019 the Consumer Financial Protection Bureau (CFPB) launched a streamlined electronic submission system, called Collect, which allows prepaid account issuers to submit their account agreements to the Bureau. Prepaid issuers can register for the system now before the April 1, 2019 effective date of the Bureau’s prepaid rule. The Bureau’s prepaid rule includes a requirement that prepaid account issuers submit their prepaid account agreements, including fee information, to the Bureau. Starting on

Recently the CFPB published a study entitled Suspicious Activity Reports on Elder Financial Exploitation: Issues and Trends. The key findings of the study indicate: SAR filings on elder financial exploitation quadrupled from 2013 to 2017. In 2017, elder financial exploitation (EFE) SARs totaled 63,500. Based on recent prevalence studies, these 2017 SARs likely represent a tiny fraction of actual incidents of elder financial exploitation. Money services businesses have filed an increasing share of EFE SARs.