The volume of change to the Truth-in-Lending Act and Regulation Z during the past year has been overwhelming. But in the midst of all the change Congress and the Consumer Financial Protection Bureau made an effort to lighten the load, a bit, for small creditors. So what breaks are available? And, who qualifies as a small creditor? Since the definition focuses, in part, on affiliates we are also concerned with who is an affiliate? Breaks […]
Category: Dodd-Frank Act
STATUS OF HMDA UPDATE
The Dodd-Frank Act has made substantial changes to the Home Mortgage Disclosure Act (HMDA). Now it appears that the regulation writing process is in high gear. Recently Richard Cordray, Director of the Consumer Financial Protection Bureau (CFPB), announced his agency is convening a Small Business Review Panel, as required by the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA). The convening of a SBREFA panel is a preliminary step in the process of releasing […]
FOLLOW-UP – COMPLIANCE REVIEW/AUDIT CONSIDERATIONS FOR 2014
We received some solid feedback to our recent article Compliance Review/Audit Considerations for 2014. Several readers thanked us for the article. Two reported that the 2014 review/audit was headed for “business as usual” until they inquired about the scope of the proposed review/audit and discovered Dodd-Frank was not included. One of the bankers is switching to another company for their 2014 and future reviews, reporting, “We have lost confidence in … (the name of their […]
PROVIDING THE LIST OF HOMEOWNERSHIP COUNSELORS
On November 8 the Consumer Financial Protection Bureau (CFPB) released a tool that provides an easy-to-use method of providing the required list of homeownership counseling organizations. Creditors can provide the list made available through the CFPB tool or may develop their own lists using the same HUD data that the CFPB uses in the tool. Some loans origination software systems (LOS) have not completed links in their software to automatically download the lists. As an […]
WHAT IS AN EFFECTIVE DATE?
Whenever federal financial institution regulatory agencies issue new final regulations they include an effective date. We have all seen, “The rule is effective January 10, 2014” or “The rule is effective for applications received on or after January 10, 2014,” but what does that mean. Apparently the term “effective date” means different things to different people. For financial institution regulatory agencies the term “effective date” apparently refers to the date by which a financial institution […]