On July 6 the Federal Reserve Board approved final rules to implement the credit score disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. If a credit score is used in setting material terms of credit or in taking adverse action, the statute requires creditors to disclose credit scores and related information to consumers in notices under the Fair Credit Reporting Act (FCRA). The final rules amend: Regulation V (Fair Credit Reporting) […]
Category: Dodd-Frank Act
NEW APPROACH FOR A BIG COMPLIANCE HEADACHE
Everyone seems to be aware of the huge challenge presented by the Dodd-Frank Act. Thousands of pages of law will become tens of thousands of pages of regulations in the next few years. But most lenders have not yet adopted a plan for dealing with this huge issue. One solution – join a masters group. Compliance Resource, LLC, through their website, mycomplianceresource.com, has formed such a group – the Dodd-Frank Masters Group. Amy Faust, Marketing […]
RULES AND ORDERS TO BE ENFORCED BY THE CFPB
On May 31st the Consumer Financial Protection Bureau (CFPB) published the list of the rules and orders it will enforce beginning on the designated transfer date of July 21, 2011. The list includes the agencies transferring rules and orders to the CFPB. The CFPB will be very busy in the coming months, and probably for several years to come. Board of Governors of the Federal Reserve 1. 12 CFR Part 202—Equal Credit Opportunity Act (Regulation […]
ABILITY TO REPAY – PROPOSED REGULATIONS
Recently the Federal Reserve Board (FRB) requested comment on a proposed rule under Regulation Z that requires creditors to determine a consumer’s ability to repay a mortgage before making the loan and also establishes minimum mortgage underwriting standards. We already have a similar requirement for Section 32 mortgages, Section 35 mortgages (higher-priced mortgage loans), and for open-end credit. The requirement is being expanded to all consumer mortgage loans (except home equity lines of credit, timeshare […]
New Regulation Z Dollar Threshold
On March 24, 2011 the Federal Reserve Board approved a change to Regulation Z that increases the threshold for transactions exempt from Regulation Z from $25,000 to $50,000. This change was mandated by the Dodd Frank Act. The change is effective on July 21, 2011. So you may be wondering – What are the details of this change? What does the change mean to my bank? DETAILS Currently, the Truth in Lending Act (TILA) exempts […]