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On February 4, 2019 the Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution letter (FIL-5-2019) dealing with voluntary private education loon rehabilitation programs. The notice was issued jointly with the Board of Governors of the Federal Reserve System (Fed). The FIL is designed to make financial institutions aware of an amendment to section 623 of the Fair Credit Reporting Act (FCRA). This amendment is contained in section 602 of the Economic, Growth, Regulatory Relief

On January 25, 2019 the Consumer Financial Protection Bureau released four Frequently Asked Questions (FAQs) Related to TRID. The first three questions deal with corrected disclosures and the three-day waiting period before closing. The final questions involves a form issue. The questions and answers are available below and by clicking here. If there is a change to the disclosed terms after the creditor provides the initial Closing Disclosure, is the creditor required to ensure the

The Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, National Credit Union Administration have issued a final rule amending their regulations regarding loans in areas having special flood hazards to implement the private flood insurance provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters Act). Prior to implementing this final rule, the agencies issued two proposed rules addressing private flood

What’s going on with military lending? Is there a pattern we should be watching? On January 17, 2019 the Consumer Financial Protection Bureau (CFPB) announced that it has asked Congress to grant the agency clear authority to supervise for compliance with the Military Lending Act (MLA). On January 24, 2019 the CFPB announceda settlement a broker of contracts offering high-interest credit to veterans. The Consent Order filed by the CFPB states that the Bureau found the

When a big bank gets hit with a big penalty I often find that community banks think it is a “big bank thing” that does not impact community banks. Big banks make the same mistakes as community banks but they do it on a bigger scale. The recent settlement between the Consumer Financial Protection Bureau (CFPB) and USAA Federal Savings Bank (USAA) is a good case in point. The CFPB found that USAA: Violated the