On April 28, 2018 the Consumer Financial Protection Bureau (CFPB) finalized an amendment to its Truth in Lending/Real Estate Settlement Procedures Act Integrated Disclosures (TRID) that addresses when a creditor may compare charges paid by or imposed on the consumer to amounts disclosed on a Closing Disclosure, instead of a Loan Estimate, to determine if an estimated closing cost was disclosed in good faith. Under the current rule, circumstances may arise in which a cost […]
Category: Lending Compliance
CFPB STATEMENT ON PAYDAY RULE
On January 16, 2018 the Consumer Financial Protection Bureau (CFPB) issued the following statement on the Payday Rule: “January 16, 2018 is the effective date of the Bureau of Consumer Financial Protection’s final rule entitled “Payday, Vehicle Title, and Certain High-Cost Installment Loans” (“Payday Rule”). The Bureau intends to engage in a rulemaking process so that the Bureau may reconsider the Payday Rule. Although most provisions of the Payday Rule do not require compliance until August […]
FINAL AMENDMENTS TO CRA REGULATIONS
During mid-November the Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies), published a final rule to amend their respective Community Reinvestment Act (CRA) regulations. The rule amends the definitions of “home mortgage loan” and “consumer loan” and the public file content requirements to conform to revisions made by the Consumer Financial Protection Bureau to its Regulation C, which implements the Home Mortgage Disclosure Act. […]
ADDITIONAL ANNUAL LENDING THRESHOLDS PUBLISHED
On November 9 the Consumer Financial Protection Bureau published additional 2018 lending compliance thresholds as follows: The HPML Appraisal Exemption Threshold contained in 1026.35(c)(2)(ii) increased from $25,500 to $26,000; and The Regulation Z Scope Thresholds contained in 1026.3(b)(1) increased from $54,600 to $55,800. The same threshold is applicable to Regulation M. Information regarding other TILA thresholds that were published in July is available at https://mycomplianceresource.com/annual-update-to-tila-dollar-amounts/ In a few weeks the remaining thresholds will be published. […]
CFPB RELEASES HMDA PLATFORM FOR BETA TESTING
Finally, HMDA covered financial institutions can view another piece to the never-ending puzzle of HMDA tools from the CFPB. The HMDA Platform was released today for beta testing. Starting with 2017 data collected, financial institutions are required to report HMDA data to the CFPB. The platform must be utilized by all HMDA reportable financial institutions to submit their data required by March 1, 2018. The Bureau did clarify the reason for the release was to […]