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PREPAID ACCOUNTS – EXAMINATION PROCEDURES

Posted by jholzknecht on  February 25, 2019
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The Federal Deposit Insurance Corporation has released examination procedures for Prepaid Accounts to incorporate the Consumer Financial Protection Bureau’s (CFPB) amendments to Regulation E and Regulation Z. The examination procedures may be helpful to financial institutions seeking to better understand how examiners will evaluate an institution’s compliance with the prepaid account rule.. On October 3, 2016, the CFPB published its Final Rule for Prepaid Accounts to create comprehensive consumer protections for prepaid accounts. Specifically, the

RURAL REMINDERS

Posted by jholzknecht on  February 16, 2019
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Category: CFPB, CRA
2019 list of rural and underserved counties The Consumer Financial Protection Bureau (CFPB) has published the 2019 list of rural and underserved counties and a separate 2019 list that includes only rural counties. The CFPB has also updated the Rural and Underserved Areas Tool (Tool) for 2019. The lists and the tool help creditors determine whether a property is located in a rural or underserved area for purposes of applying certain regulatory provisions related to mortgage loans.

REVISED UNIFORM RESIDENTIAL MORTGAGE LOAN APPLICATION: WHAT YOU NEED TO KNOW NOW

Posted by Brent V on  February 15, 2019
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Revised Uniform Residential Mortgage Loan Application: What You Need to Know Now Every mortgage lender has to make some tough decisions in the coming months about how to handle the revised uniform residential mortgage loan application.  The following video provides some basic information about the revision process.  

COMPLIANCE RISK – READING BUT NOT ACTING

Posted by jholzknecht on  February 9, 2019
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In late 2017 the FDIC’s Dallas Region Quarterly Newsletter contained an article entitled Automated Overdraft Program and One-Time Debit and ATM Opt-In Procedure Considerations. The article described a situation observed in several examinations regarding overdraft programs and the interplay with Regulation E opt-in requirements. The well-written article concluded with the following admonition, “If you self-identify violations or potential issues described in this article, management should immediately modify procedures to prevent consumer harm, identify any customers

CFPB ISSUES PROPOSAL TO DELAY AND RESCIND PAYDAY LENDING UNDERWRITING RULES

Posted by jholzknecht on  February 8, 2019
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Category: CFPB, Lending Compliance
On February 6, 2019 the Consumer Financial Protection Bureau issued two notices of proposed rulemaking (NPRM) related to the Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (2017 Payday Lending Rule). As finalized, the 2017 Payday Lending Rule has two primary parts: 1) Subject to certain exceptions, for short-term and longer-term loans with balloon payments, it is unfair and abusive for a lender to make such loans without determining that consumers have the ability
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