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 […]
Category: Lending Compliance
2019 CRA THRESHOLDS PUBLISHED
On December 20, 2018 the Federal Deposit Insurance Corporation, Federal Reserve Board of Governors, and the Office of the Comptroller of the Currency, together referred to as the Agencies, published the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. Annual adjustments to these asset-size thresholds are based on the change in the average of […]
REQUEST FOR INFORMATION ON SMALL DOLLAR LENDING
On November 14, 2018 the FDIC issued a nine-page request for information on small dollar lending, including steps that can be taken to encourage FDIC-supervised financial institutions to offer small-dollar credit products that are responsive to customers’ needs and that are underwritten and structured prudently and responsibly. The request was issued as FIL-71-2018. Comments will be accepted for 60 days following publication in the Federal Register, which is expected soon. The FDIC recognizes the important […]
NATIVE AMERICAN DISCRIMINATION
Recently the U.S. Department of Housing and Urban Development (HUD) approved a Conciliation Agreement resolving claims brought by three homeowners, a couple and an individual, against loanDepot.com, LLC, and Appraisal Management Services of America, Inc. The three alleged that the lender refused to refinance their homes because they are on Native American lands. The individual also claimed that loanDepot.com would not refinance his house because he is Native American. The Fair Housing Act prohibits housing […]
REGULATION Z – SELECTED 2019 THRESHOLDS
On August 27, 2018 the Consumer financial Protection Bureau (CFPB published a final rule amending Regulation Z. The Bureau is required to calculate annually the dollar amounts for several provisions in Regulation Z; this final rule revises, as applicable, the dollar amounts for provisions implementing TILA and amendments to TILA, including under: The Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act); The Home Ownership and Equity Protection Act of 1994 (HOEPA); and […]