On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]
Category: Regulation B
CFPB PUBLISHES FALL 2019 UNIFIED AGENDA
Recently the Consumer Financial Protection Bureau (CFPB) published its Fall 2019 rulemaking agenda. The agenda identifies the regulatory matters that the CFPB reasonably anticipates having under consideration during the period from October 1, 2019 to September 30, 2020. The following summaries a few key topics: Proposed Fair Debt Collection Rule (Regulation F) – The CFPB proposed Regulation F in May 2019. Now the CFPB is testing consumer disclosures related to time-barred debt and, after testing, […]
HAS REDLINING ENFORCEMENT RETURNED?
At the end of the Obama administration redlining consent decrees were becoming coming. Redlining cases, once the purview of large banks, had drifted down to the community bank level. Since the beginning of 2016 redlining cases have dried up, other than one case left over from the prior administration that was settled favorably for the bank. On June 13, 2009 The Department of Justice (DOJ) and the U.S. Attorney’s Office for the Southern District of […]
URLA – THE MOST RECENT OFFICIAL APPROVAL
On November 20, 2017 the Consumer Financial Protection Bureau (CFPB) published its most recent Official Approval of the redesigned Uniform Residential Loan Application (URLA) to include an applicant language preference question. The first Official Approval of the URLA, which was issued by the CFPB on September 23, 2016: • Clarified that the relevant language in the redesigned URLA is in compliance with the regulatory provisions of Regulation B § 1002.5(b) through (d), regarding requests for […]
URLA IMPLEMENTATION TIMELINE
On September 26, 2017 Fannie Mae and Freddie Mac (the GSEs) published guidance on the implementation timeline for the redesigned Uniform Residential Loan Application (URLA). Demographic Information Addendum The Consumer Financial Protection Bureau (CFPB) has finalized their Technical Corrections and Clarifying Amendments to the Home Mortgage Disclosure Act (HMDA) Regulation C. The GSEs have updated the Demographic Information Addendum based on this final rule. The changes were made only to the form instructions and not […]