The Payday, Vehicle Title, and Certain High-Cost Installment Loans (Payday Loan) Rule has been unfolding for years. Parts of the rule officially took effect on August 19, 2019; the Consumer Financial Protection Bureau (CFPB) has delayed the underwriting rules until November 19, 2020, and has further proposed eliminating those rules altogether. The August 19 date has been temporarily postponed by a court order. Some lenders need to build a comprehensive compliance management system (CMS) to […]
Category: CFPB
REMITTANCE TRANSFER RULE CONSENT ORDER
On August 27, 2019 the Consumer Financial Protection Bureau (CFPB) announced a settlement with Maxitransfers Corporation (Maxi), a company that serves consumers looking to send money overseas. This is the CFPB’s first enforcement action based on violations of the Remittance Transfer Rule, which implements the Electronic Fund Transfer Act (EFTA). Maxi provides remittance transfer services from more than 1,600 third-party locations in the U.S., such as grocery stores and pharmacies, to over 19,500 payment locations […]
PROPOSED HMDA CHANGES – COMMENT PERIOD EXTENDED
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
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 […]
QM Changes Considered
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 […]