Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements […]
Category: Regulation C
REVISED HMDA RULES PUBLISHED
On October 15, 2015 the Consumer Financial Protection Bureau (CFPB) published revised Regulation C rules, which implement the Home Mortgage Disclosure Act. The revisions are effective for the most part on January 1, 2018, certain provisions are phased in through January 1, 2020. The revisions impact: Coverage – Coverage rules are slightly revised, but do not qualify as a major item on anyone’s list. The CFPB is playing this as meaningful reduction of regulatory burden. […]
WHEN DO WE HAVE AN APPLICATION?
We have had several recent questions on this topic. What constitutes an application for TRID is very different from the concept of “application” for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C. It would take a large book to thoroughly explore all the nuances of “applications” under federal laws. This article explores only a few basic concepts. Regulation Z Under Section 1026.2(a)(3)(ii), for transactions subject to […]
CHANCE TO BREATHE
I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real […]
2015 HMDA ISSUES
The January 2015 issue of the FFIEC’s CRA/HMDA Reporter has several good reminders about HMDA issues. The lead article, HOEPA Changes and New Edit Changes, focuses on changes to Regulation Z (HOEPA) rules that were effective in January 2014 and impacted the 2014 HMDA data just submitted by your bank. The changes lowered the rate spread threshold of HOEPA eligible loans, and expanded coverage to certain home purchase mortgage products. The Reporter is available by […]