On January 27, 2020 the Consumer Financial Protection Bureau (CFPB) published, in the Federal Register, a Policy Statement that announces a new designation for certain guidance, known as “Compliance Aids,” and to explain the legal status and role of guidance with that designation. Examples of compliance aids previously released by the CFPB include small entity compliance guides, instructional guides for disclosure forms, executive summaries, summaries of regulation changes, factsheets, flow charts, compliance checklists, frequently asked […]
Category: CFPB
2020 HOME MORTGAGE DISCLOSURE ACT THRESHOLD INCREASE
On December 20, 2019 the Consumer Financial Protection Bureau published a final rule amending the official commentary that interprets the requirements of Regulation C (Home Mortgage Disclosure Act) to reflect the asset-size exemption threshold for banks, savings associations, and credit unions based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). For 2020 the exemption is increased to $47 million from $46 million. […]
TRID CONSTRUCTION LOAN GUIDES
On Wednesday, Dec. 18, 2019, the Consumer Financial Protection Bureau (CFPB) published two guides on disclosing construction-only and construction-permanent loans with examples based on common questions received by the Bureau. The Combined Guide provides guidance for disclosing the phases together and the Separate Guide provides guidance for disclosing the phases separately. Alternate Headline: CFPB Publishes Inadequate TRID Construction Loan Guidance More Than Four Years After the Effective Date Have you ever heard the old saying , “a day late […]
CFPB PUBLISHES FALL 2019 UNIFIED AGENDA
Recently the Consumer Financial Protection Bureau (CFPB) published its Fall 2019 rulemaking agenda. The agenda identifies the regulatory matters that the CFPB reasonably anticipates having under consideration during the period from October 1, 2019 to September 30, 2020. The following summaries a few key topics: Proposed Fair Debt Collection Rule (Regulation F) – The CFPB proposed Regulation F in May 2019. Now the CFPB is testing consumer disclosures related to time-barred debt and, after testing, […]
CFPB COMMENCES TRID ASSESSMENT
On November 20 the Consumer Financial Protection Bureau (CFPB) announced that it commencing an assessment of its TRID (Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure) rules. The CFPB intends to address the TRID Rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors. The public is invited to comment on the feasibility and effectiveness of […]