On May 31st the Consumer Financial Protection Bureau (CFPB) published the list of the rules and orders it will enforce beginning on the designated transfer date of July 21, 2011. The list includes the agencies transferring rules and orders to the CFPB. The CFPB will be very busy in the coming months, and probably for several years to come. Board of Governors of the Federal Reserve 1. 12 CFR Part 202—Equal Credit Opportunity Act (Regulation […]
Category: Lending Compliance
FREE TRAINING RESOURCE FOR BANK DIRECTORS
The Federal Reserve Bank of Kansas City has an amazing free training resource for bank directors, aptly named Training for Bank Directors. The information is available at: https://www.bankdirectorsdesktop.org/training.cfm?m=01&l=01&s=1.htm. The computer based training includes approximately fifty modules covering the following topics: * What is a Bank? * Regulatory Structure * Regulatory Compliance * Bank Safety and Soundness * When Things Go Wrong The material is basic. You will not be granting PhDs in banking to directors […]
ABILITY TO REPAY – PROPOSED REGULATIONS
Recently the Federal Reserve Board (FRB) requested comment on a proposed rule under Regulation Z that requires creditors to determine a consumer’s ability to repay a mortgage before making the loan and also establishes minimum mortgage underwriting standards. We already have a similar requirement for Section 32 mortgages, Section 35 mortgages (higher-priced mortgage loans), and for open-end credit. The requirement is being expanded to all consumer mortgage loans (except home equity lines of credit, timeshare […]
New Regulation Z Dollar Threshold
On March 24, 2011 the Federal Reserve Board approved a change to Regulation Z that increases the threshold for transactions exempt from Regulation Z from $25,000 to $50,000. This change was mandated by the Dodd Frank Act. The change is effective on July 21, 2011. So you may be wondering – What are the details of this change? What does the change mean to my bank? DETAILS Currently, the Truth in Lending Act (TILA) exempts […]
MOST RECENT RESPA ROUNDUP
The Department of Housing and Urban Development (HUD) recently published an issue of its periodic newsletter – RESPA ROUNDUP. This issue provides guidance on several issues related to the Good Faith Estimate (GFE) and the Uniform Settlement Statement (HUD-1). The articles include: * HUD-1 Line 803 Tolerance Violation; * Credit Report Charges; * Loan Originator Fails to Issue GFE; and * 4506-T 9Tax Transcript Fees. We must be totally crazy to write and read about […]