On March 20, 2023, the Consumer Financial Protection Bureau (CFPB) published a final rule to make non-substantive corrections and updates to CFPB and other Federal agency contact information found at certain locations in Regulations B, E, F, J, V, X, Z, and DD, including Federal agency contact information that must be provided with: The Equal Credit Opportunity Act adverse action notices; and The Fair Credit Reporting Act Summary of Consumer Rights. This final rule also revises the […]
Category: Regulation Z
TRID DISCLOSURES FOR CONSTRUCTION LOANS – ARE REVISIONS POSSIBLE?
On February 27, 2023, the Consumer Financial Protection Bureau (CFPB) published a blog article regarding efforts by the Independent Community Bankers of America (ICBA) to gain approval for an application regarding consumer disclosures of a loan that provides either construction or construction-permanent financing In its April 28, 2022 application, the ICBA states it is not uncommon in rural communities for first-time homebuyers to build their first home because there are limited existing affordable “starter” homes. The […]
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DT) begins on Sunday March 12, 2023 at 2:00 a.m. It ends on November 5, 2023 at 2:00 a.m. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in […]
FINAL THRESHOLD UPDATE FOR 2022
I bet you thought that you were all wrapped up on your compliance news for 2022, huh? Well…not so fast! On December 28, 2022, The CFPB released the final HMDA threshold and the remaining Regulation Z thresholds. The HMDA threshold was increased from $50 million in 2022 to $54 million in 2023. The HPML Small Creditor Threshold was increased from $2.336 billion to $2.537 billion in 2023. The HPML Intermediate Creditor Threshold was increased from […]
HAPPY HOLIDAYS AND A THRESHOLD UPDATE
We hope you enjoyed Christmas or the holiday you enjoy with your family. And, we hope the New Year holds great promise for you all. Annual Thresholds On December 22, 2022, we published a blog article entitled Final Regulation Z Thresholds. We had an error when loading the article to our website. The Qualified Mortgage thresholds for the spread between the annual percentage rate (APR) and the average prime offer rate (APOR) were misstated. The corrected […]