It’s that time of year again. Daylight Saving Time, or Daylight Time (DT), ends on November 5, 2017 at 2:00 a.m. If your financial institution is in an area that observes Daylight Savings Time, ensure the time zone designation has been updated to reflect Standard Time (ST) on your TRID disclosures. Under the TRID rules in Regulation Z creditors must disclose the date and time (including the applicable time zone): When the interest rate lock […]
Category: Lending Compliance
CFPB UPDATES HMDA TOOLS
Earlier today the Consumer Financial Protection Bureau (CFPB) updated several Home Mortgage Disclosure Act (HMDA) tools available on their website. The updates are the result of recent amendments to Regulation C. The updated tools (click link to access) include the: 2018 HMDA institutional coverage chart , 2018 HMDA transactional coverage chart , and Key dates timeline . For additional information about recent HMDA revisions click on the following links: Proposed HMDA Disclosure Policy; HMDA Examiner Transaction Testing Guidelines; […]
ANNUAL UPDATE TO TILA DOLLAR AMOUNTS
On July 25, 2017 the Consumer Financial Protection Bureau (CFPB) approved a final rule that amends various dollar amounts that impact requirements of the Truth in Lending and Act and Regulation Z. The rule was published on August 30, 2017. This is an annual event. The revised amounts are effective on January 1, 2018. Be sure to update your procedures and systems to reflect the revised amounts as of the effective date. The revised amounts: For […]
REGULATION O – LENDING TO INSIDERS
Congress enacted the Financial Institutions Regulatory and Interest Control Act in 1978. The insider lending provisions of the law were implemented as Regulation O. Historical data show that insider abuse is at the heart of many bank failures. Examiners take very seriously their mission to prevent insider abuse. They frequently cite violations of Regulation O during examinations, and often take enforcement action. Enforcement actions may take the form of civil monetary penalties , a Memorandum of […]
JUST A LITTLE OVER THE LIMIT
From time-to-time I have identified a practice as “a violation, but a low-risk violation.” That’s kind of like driving 58 miles per hour in a 55 miles per hour zone. It is “a violation of law, but a low-risk violation.” Recently I was asked if it was OK to take a realtor to lunch to build a better relationship that should lead to more referrals of loan applications. I responded that the practice is… You […]