Archive

PROVIDING REALTORS COPIES OF THE CLOSING DISCLOSURES

We have received numerous reports that realtors involved in purchase transactions are requesting (demanding) copies of the borrower’s closing statement. Some realtors have included language (see sample below) in the purchase contract to ensure they receive the closing disclosure.  “All parties to this transaction, including buyers, sellers, real estate agents, lender, and closing agents acknowledge that the TRID Closing Disclosure, the Buyers Statement, the Sellers Statement, or any other summary form of the transaction does […]

AMENDMENTS TO PRIVACY LAW

The Gramm-Leach-Bliley Act (GLBA) requirement to provide an annual privacy notice has been amended by Title LXXV of the Fixing America’s Surface Transportation Act or the FAST Act of 2015 (Public Law 114-94), enacted on December 4, 2015. The FAST Act amends Section 503 of the GLBA to create an exception to the annual privacy notice requirement for financial institutions that: Do not share nonpublic personal information in any way that requires an opt-in under […]

CFPB PRIVACY PROPOSAL PROMOTES MORE EFFECTIVE DISCLOSURES: GOOD NEWS

On May 6, 2014, the Consumer Financial Protection Bureau (CFPB) proposed a rule that would amend Regulation P, Privacy of Consumer Financial Information.  The proposed rule would promote more effective privacy disclosures from financial institutions to their customers, while also providing some good news for banks. Currently financial institutions send annual privacy notices to their customers that describe if and how consumer’s nonpublic personal information will be shared.  If the institution shares information with an […]