Earlier this week the Consumer Financial Protection Bureau (CFPB) published a article and issued a bulletin on the topic of Social Security disability income. In our November 10th article on the same topic we warned you of the discrimination risk involved in verifying this type of income. Now you can hear the same message from the CFPB. In the past, Social Security disability income recipients have faced special challenges in providing proof that their disability […]
Category: Regulation B
ECOA DISCRIMINATION CASE
The Sixth Circuit dismissed an Equal Credit Opportunity Act (ECOA) lawsuit because the plaintiffs failed to make a case that the creditor denied their request for a loan restructuring for a discriminatory reason. 16630 Southfield Ltd. Partnership v. Flagstar Bank, F.S.B., 727 F.3d 502 (6th Cir. 2013). The plaintiffs, one of whom was a naturalized U.S. citizen from Iraq, obtained a loan for a real estate venture. The loan was later restructured when the plaintiffs […]
COLLECTING GOVERNMENT MONITORING INFORMATION
The Fourth Quarter 2013 issue of Consumer Compliance Outlook, published by the Board of Governors of the Federal Reserve Board, contains an excellent article which reviews and compares the rules for collecting Government Monitoring Information (GMI) under Regulations B (Equal Credit Opportunity Act) and Regulation C (Home Mortgage Disclosure Act). The article is available here.
MORE FINAL REVISED RULES – REGULATIONS B, X, AND Z
On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]
MOST RECENT CFPB SEMI-ANNUAL RULEMAKING AGENDA
Recently the Consumer Financial Protection Bureau (CFPB) published its most recent semiannual rulemaking agenda. There were no big surprises in the agenda. This article reviews three issues of concern. Integrated Disclosures and Finance Charge Rules – The biggest rules yet to be finalized are the new integrated disclosures. The disclosures include the loan estimate (that combines the early TIL disclosure and the good faith estimate) and the closing disclosure (that combines the final TIL disclosures […]