Have your customers been asking about virtual currencies, such as Bitcoin? Do you have answers for their questions? Occasionally the Consumer Financial Protection Bureau (CFPB) lives up to their name. Recently the CFPB published a very helpful Consumer Advisory entitled Risks to Consumers Posed by Virtual Currencies. The Advisory explains how virtual currencies work and various risks associated with the product. It includes several real world stories of losses resulting from fraud and mishandling of virtual currencies. […]
Category: CFPB
ATR/QM POLL
Recently we polled our Compliance Master Group members on the Ability-to-Repay/Qualified Mortgages rules. There were no huge surprises, but we got a lot of confirmation of what we expected to see: Most creditors use a mix of ATR/QM options; The Small Creditor QM is the most popular ATR/QM option; Adopting the ATR/QM rules was a challenge, but did not reduce loan volume for most creditors; and Most creditors have not yet adopted Appendix Q, but […]
HMDA PROPOSAL PUBLISHED
On July 24, 2104 the Consumer Financial Protection Bureau (CFPB) published proposed rules to implement changes to the Home Mortgage Disclosure Act (HMDA). Some of the proposed changes are mandated by the Dodd-Frank Act, others are part of a CFPB effort to modernize and streamline regulations. Comments on the 572-page proposal are due on or before October 22, 2014. Coverage There had been speculation that coverage would be expanded to all mortgage lenders that originated […]
ABILITY TO REPAY – SUCCESSORS-IN-INTEREST
On July 11, 2014 the Consumer Financial Protection Bureau (CFPB) released a 10-page rule that clarifies that where a successor-in-interest (successor) who has previously acquired title to a dwelling agrees to be added as obligor or substituted for the existing obligor on a consumer credit transaction secured by that dwelling, the creditor’s written acknowledgement of the successor as obligor is not subject to the Ability-to-Repay Rule (ATR Rule), § 1026.43, because such a transaction does […]
EQUAL TREATMENT FOR SAME-SEX MARRIED COUPLES
On June 26, 2013, in United States v. Windsor, the U.S. Supreme Court struck down Section 3 of the Defense of Marriage Act as unconstitutional. The Consumer Financial Protection Bureau (CFPB) has noted on its blog that the decision has important consequences for its work. In order to fully implement the decision, the CFPB has taken steps to clarify how the decision affects the rules for which the agency is responsible. Recently, CFPB Director Cordray issued a […]