Archive

CONSIDERATION OF RELIGION IN A BUSINESS LOAN APPLICATION

On December 9, 2021, the CFPB issued a Supervisory Highlights report, which shines a light on legal violations identified by the CFPB’s examinations in the first half of 2021. A surprising item on the list was that CFPB examiners found that lenders improperly considered small business applicants’ religion in their credit decisions. For religious institutions applying for small business loans, some lenders improperly utilized a questionnaire that contained explicit inquiries about an applicant’s religion. Following […]

TRID AND THE END OF DAYLIGHT SAVING TIME

Daylight Saving Time (DT) ends on November 7, 2021 at 2:00 a.m. What does DST have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas that observe DT need to remember to change the […]

REGULATION Z CONSUMER CREDIT EXEMPTION AND HPML APPRAISAL THRESHOLDS UNCHANGED FOR 2021

On November 18 the Consumer Financial Protection Bureau (CFPB) and Federal Reserve Board (FRB) published the 2021 threshold for the consumer credit exemption in Regulations Z and M. Additionally, the CFPB, FRB, and Office of the Comptroller of the Currency (OCC) published the 2021 threshold for Higher Priced Mortgage Loan (HPML) appraisal exemption in Regulation Z. There will be no changes from the 2020 threshold amounts. The thresholds for 2021 are as follows: The protections […]

NMLS REGISTRATION RENEWAL BEGINS NOVEMBER 1

It’s that time of year again…the Nationwide Multistate Licensing System and Registry’s (NMLS) renewal period for 2021 begins November 1 and continues through December 31, 2020. All Mortgage Loan Originators (MLO), as defined in Regulation G, 12 CFR 1007, who are registered with the Registry are required to complete the annual registration renewal. One exception to the renewal requirement is for MLOs who completed their initial registration with the Registry less than six months prior […]

CORONA RELIEF – ECOA VALUATION RULE

On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]