The Dodd-Frank Act (DFA) requires the CFPB to review certain rules within five years after they take effect. The required reviews are called assessments. The CFPB is conducting an assessment of the ATR/QM rule, and will issue a report of the assessment by January 2019. As required by law, the assessment will address the rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act and the specific goals of the […]
Category: CFPB
JUST A LITTLE OVER THE LIMIT
From time-to-time I have identified a practice as “a violation, but a low-risk violation.” That’s kind of like driving 58 miles per hour in a 55 miles per hour zone. It is “a violation of law, but a low-risk violation.” Recently I was asked if it was OK to take a realtor to lunch to build a better relationship that should lead to more referrals of loan applications. I responded that the practice is… You […]
PREPAID RULE LIVES TO FIGHT ANOTHER DAY
For those banks that fervently prayed the almost 1,700-page Prepaid Account rule would be banished by the Party of Lincoln – sorry but it survived the recent round of regulatory rollbacks. Courtesy of the law firm, Ballard Spahr, and its Consumer Finance Monitor (CFM) webpage and Politico, we have learned that the joint resolutions introduced in the Senate and House in February to kill the upcoming Prepaid Account regulation, died on the vine of apathy. […]
CFPB SERVICING RULE FIASCO
On May 4th the Consumer Financial Protection Bureau (CFPB) announced plans to assess the effectiveness of the Real Estate Settlement Procedures Act (RESPA) mortgage servicing rule. The announcement accurately reports that the CFPB issued the 2013 RESPA Servicing Final Rule in January 2013. That rule was amended a few times before it took effect on January 10, 2014. The Dodd-Frank Act requires the CFPB to conduct assessments of certain rules within five years after they […]
PROPOSED CHANGES TO REGULATIONS B AND C
The CFPB has been busy with proposed changes in recent weeks. Two proposed changes released by the CFPB will impact most financial institutions to some degree. The CFPB released proposed changes to Regulation B on March 24, 2017. The proposal is designed to permit creditors additional flexibility in complying with Regulation B – ECOA, in order to facilitate compliance with Regulation C – HMDA. This proposal was not unexpected. In addition, the CFPB released changes […]