On July 25 the Consumer Financial Protection Bureau (CFPB) published a 30-page Advance Notice of Proposed Rulemaking (ANPR) seeking comments relating to the scheduled January 10, 2021, expiration of the temporary qualified mortgage provision applicable to loans eligible for purchase or guarantee by the Government Sponsored Enterprises, Fannie Mae and Freddie Mac. That provision is in the CFPB’s Ability to Repay/Qualified Mortgage (ATR/QM) Rule (section 1026.43 of Regulation Z). The Bureau is considering whether […]
Category: Lending Compliance
PAYDAY LENDER UNDERWRITING RULES DELAYED
On June 6 2019, the Consumer Financial Protection Bureau (CFPB) issued a final rule to delay the August 19, 2019 compliance date for the mandatory underwriting provisions of the 2017 Payday Lending Rule to November 19, 2020. The payday lender rules were initially proposed in June 2016 with a final rule issued in October 2017 and published in the Federal Register on November 17, 2017. The rule was effective on January 16, 2018 with a […]
2019 ABA Regulatory Compliance Conference
Today marked the first day of the 2019 ABA Regulatory Compliance Conference in New Orleans, LA. The sessions went off without a hitch, but the recent storms across the country caused many flight delays and cancellations leaving some behind. Those who were able to attend the Sunday sessions were tasked with trying to decide which sessions to attend first. Planning out your daily agenda takes some organization, but there are plenty of topics to keep […]
CFPB ISSUES PROPOSAL TO DELAY AND RESCIND PAYDAY LENDING UNDERWRITING RULES
On February 6, 2019 the Consumer Financial Protection Bureau issued two notices of proposed rulemaking (NPRM) related to the Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule (2017 Payday Lending Rule). As finalized, the 2017 Payday Lending Rule has two primary parts: 1) Subject to certain exceptions, for short-term and longer-term loans with balloon payments, it is unfair and abusive for a lender to make such loans without determining that consumers have the ability […]
CFPB ISSUES TRID GUIDANCE
On January 25, 2019 the Consumer Financial Protection Bureau released four Frequently Asked Questions (FAQs) Related to TRID. The first three questions deal with corrected disclosures and the three-day waiting period before closing. The final questions involves a form issue. The questions and answers are available below and by clicking here. If there is a change to the disclosed terms after the creditor provides the initial Closing Disclosure, is the creditor required to ensure the […]