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Generally, a consumer has three business days after consummation to rescind a transaction, but if the creditor fails to provide a proper notice of the right to cancel or proper material disclosures, the period is extended to three years. Recent decisions issued by the Fourth and Tenth Circuits reached different conclusions on whether a lawsuit is necessary to the timely exercise of the right of rescission. Gilbert v. Residential Funding LLC, 678 F.3d 271 (4th […]

The Federal Deposit Insurance Corporation (FDIC) recently announced (FIL-41-2012) a revision to the classification system for citing violations identified during compliance examinations. The revisions better communicate the severity of violations and help distinguish more serious violations from those more technical in nature. Violations are assigned to one of three classifications based primarily on the impact on the consumer. The three levels are: Level 3/High Severity – includes violations that may result in restitution to consumers […]

Are you looking for help to keep up with all the regulatory changes?  Compliance Resource, LLC is offering a free preview session of their Compliance Masters Group (CMG) this Friday, September 28th from 11-12pm EDT.  During the one hour preview session you will be shown what a typical CMG session is all about.  CMG members receive policies, procedures, director/ senior management updates, and much more.  If you are interested in attending please email Amy Faust at amy@mycomplianceresource.com.  Amy […]

Following our recent article about testing the integrated mortgage disclosure forms we received several inquiries requesting more information about the process, particularly about submitting a comment. This article responds to those requests. The Issue – The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Over 2,400 pages of proposed regulations have been published in just the past two months alone. A huge bank can assign a team to the task of […]

HMDA data for 2011 was recently made available. The data include disclosure statements for each financial institution, aggregate data for each metropolitan statistical area (MSA), nationwide summary statistics regarding lending patterns, and Loan/Application Registers (LARs) for each financial institution (LARs are modified to protect borrower privacy). For 2011:   The number of reporting institutions of 7,632 fell nearly 4 percent from the number in 2010, continuing a downward trend since 2006, when HMDA coverage included […]