The one provision of the Dodd-Frank Act that strikes fear in the heart of bankers is the requirement to collect and report HMDA-like information on business loans. The provision is supposed to be effective on July 21, 2011. But since we don’t even have proposed regulations yet, we have suspected for some time now that the provision will be delayed. Leonard Kennedy, the recently appointed General Counsel of the Consumer Financial Protection Bureau, has made […]
Category: Dodd-Frank Act
THE YEAR OF UNCERTAINTY
We are living in the time of the most overwhelming change to lending compliance rules and to the structure of the regulatory agencies that enforce the rules since civil rights and consumer protection rules were first written in the late 1960s. We hope the picture will soon develop enough so we can discern the future of compliance. While the Fed has already begun to wind down it’s regulation writing activities, as evidenced by shelving the […]
REGULATION Z – NEW FINAL RULE INCREASES DOLLAR LIMIT ON COVERED TRANSACTIONS
On March 25th the Federal Reserve Board adopted a new rule that expands the coverage of Regulation Z to credit transactions of higher dollar amounts. The final rule amends Regulation Z to implement a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Effective July 21, 2011, the Dodd-Frank Act requires that the protections of the Truth in Lending Act (TILA) apply to consumer credit transactions up to $50,000, compared with $25,000 currently. […]
REGULATION Z – NEW FINAL RULES FOR CREDIT CARDS
On March 18th the Federal Reserve Board approved a rule amending Regulation Z (Truth in Lending) to clarify prior rules implementing the Credit Card Accountability Responsibility and Disclosure Act of 2009 (Credit Card Act). The rule enhances protections for consumers who use credit cards and resolves areas of uncertainty so that card issuers fully understand their compliance obligations. The Credit Card Act requires that, before opening a new credit card account or increasing the credit […]
WHAT’S UP WITH ESCROWS
On February 23, 2011 the Federal Reserve Board issued a final rule and requested public comment on a second rule under Regulation Z to revise the escrow account requirements for certain home mortgage loans. The revisions to the regulation, which implements the Truth in Lending Act (TILA), are being made pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act. The final rule implements a provision of the Dodd-Frank Act that increases the annual […]