Daylight Saving Time (DT) begins on March 13, 2016. What does that 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 DT need to remember to change the time designation used […]
Category: Regulation Z
WHO SAID URBAN LIFE IS THE BEST LIFE?
Have you ever seen so many financial institutions wanting to do business in rural areas? The CFPB has provided yet another glimmer of hope for smaller financial institutions hoping to qualify as a small creditor. The Bureau announced yesterday, March 2, 2016, a new application process for smaller financial institutions to submit a request to determine if areas not currently deemed “rural” may be able to receive this coveted designation under federal consumer financial law. […]
TRID CORRECTION PUBLISHED BY CFPB
Can you believe that title? The CFPB has actually published something for us in writing in the Federal Register that will clear up an item that has been a source of confusion since prior to the implementation of TRID. The publication in the Federal Register dated yesterday, February 10th, results in a correction to the Supplementary Information of the final rule to correct a typographical error. Specifically, section 1026.19(e)(3)(iii) – Variations Permitted for Certain Charges […]
FURTHER CHANGES TO “RURAL OR UNDERSERVED”
Congress passed the FAST (Fixing America’s Surface Transportation Act) Act on December 4, 2015. Title LXXXIX of the FAST Act is the Helping Expand Lending Practices in Rural Communities Act of 2015 (HELP Rural Communities Act). Congress removed the word “predominantly” from the phrase “operates predominantly in rural or underserved areas” in sections 129C and 129D of the Truth in Lending Act. The phrase is used to define, in part, which creditors are permitted to make […]
REQUIRED TRAINING FOR LOAN ORIGINATORS
On January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published final rules to revise the Truth in Lending Act (TILA) to require creditors to establish and maintain loan originator qualification requirements. One of the qualification requirements mandates that the creditor provide adequate training for loan originators. The final rules were effective on January 1, 2014. Failure to provide periodic training for loan originators is a double violation of the Truth in Lending Act and […]