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 […]
Category: Regulation Z
FINAL REGULATION Z THRESHOLDS
On December 23, 2022, the Consumer Financial Protection Bureau (CFPB) will issue a final rule amending the regulation text and official interpretations for Regulation Z, which implements the Truth in Lending Act (TILA). The CFPB is adjusting these amounts, where appropriate, based on the annual percentage change reflected in the Consumer Price Index (CPI) in effect on June 1, 2022. The revisions include: For open-end consumer credit plans under TILA, the threshold that triggers requirements […]
CFPB PUBLISHES A REVISED HELOC BOOKLET
On December 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, ‘‘What You Should Know about Home Equity Lines of Credit,’’ also known as the HELOC booklet, required by the Truth in Lending Act (TILA), as implemented by Regulation Z. The CFPB is updating the HELOC booklet so that it aligns with the CFPB’s educational efforts, to be more concise, and to improve readability and usability. New features […]
$6 MILLION PENALTY FOR REGULATION Z VIOLATIONS
On September 27, 2022, the Office of the Comptroller of the Currency imposed a $6 million penalty on Sterling Bank and Trust of Southfield, MI for engaging in unsafe and unsound banking practices, including violations of the Truth in Lending Act and Regulation Z. Between approximately mid-2011 and December 2019, the Bank: Offered the Advantage Loan Program (“ALP”), a low-document mortgage loan program, which was the Bank’s primary loan product during this period. The Bank […]
DAYLIGHT SAVING TIME TRID REMINDER
Daylight Saving Time (DST) ends on November 6, 2022 at 2:00 a.m. What does DST 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 areas that observe DST need to remember to change the […]