Many lenders use the Treasury Index, specifically the weekly and monthly averages, as an index for adjustable rate mortgages. The applicable index plus the internal margin set by the lender determines the interest rate that will be charged on an adjustable rate mortgage. Lenders have historically retrieved the Treasury Index weekly and monthly averages from the H.15 report (the Selected Interest Rates report published by the FRB). As of October 11, 2016, the Federal Reserve […]
Category: Compliance Management
CONSUMER COMPLIANCE RATING SYSTEM REVISIONS – WE’RE FROM THE GOVERNMENT AND WE’RE HERE TO HELP YOU!
On November 7th, the FFIEC finalized the issuance of its updated Interagency Consumer Compliance Rating System (“CCRS”). The press release that accompanied the revision stated that the document was intended to “more fully align the rating system with the FFIEC agencies current risk-focused, tailored examination approaches” and that “the rating system’s adoption will represent no additional regulatory burden for financial institutions”. Or does it? So, far so good as we’ve all long known, through various […]
IMPACT OF THE ELECTION
Following this week’s election we all need to evaluate the impact on our lives, families, and our businesses. Change is definitely coming, but will not happen overnight. If you have a positive view of the future I hope your vision comes true. If you are fearful of the future I hope your fears are unfounded. We need to closely watch the actions of Congress and the White House over the next few years to judge […]
SET YOUR CLOCKS BACK AND CHECK YOUR TRID DISCLOSURES
Correction 10/27/2016: This article, initially posted on Wednesday, October 26th, 2016, included the designation “Eastern” in the first two paragraphs. All references to the designation “Eastern” have been removed from these paragraphs. It’s that time of year again. Daylight Saving Time, or Daylight Time (DT), ends on November 6, 2016 at 2:00 a.m. If your financial institution is in an area that observes Daylight Savings Time, ensure the time zone designation is updated to reflect […]
REGULATION BY ENFORCEMENT
The CFPB has been criticized for providing guidance in the form of enforcement actions rather by writing regulations. Expect more of the same. In a March 9, 2016 speech Director Cordray confirmed that consent orders that accompany the Bureau’s public enforcement actions, “provide detailed guidance for compliance officers across the marketplace about how they should regard similar practices at their own institutions. If the same problems exist in their day-to-day operations, they should look closely […]