Can we see the light at the end of the tunnel? Maybe faintly. Truth-in-Lending/RESPA Integrated Disclosures (TRID) – The biggest pending issue is the TRID rules that are effective August 1, 2015. Some vendors have delivered updates to loan origination software for testing. Policies, procedures, and training need to be completed. But it is appears likely that most lending institutions will complete all required tasks by the deadline. Some, like the banker I talked to […]
Category: Regulation Z
SCOTUS – RESCISSION CASE
As we originally reported in Spring 2014 the Supreme Court of the United States (SCOTUS) granted review in the case of Jesinoski v. Countrywide Home Loans. In the case, argued on November 4, 2014, and decided January 13, 2015, SCOTUS reversed and remanded the decision of the Eighth Circuit Court of Appeals. In a unanimous opinion delivered by Justice Scalia, the court held that a “borrower exercising his right to rescind under the Act need only provide written […]
CFPB PROPOSAL IMPACTS SMALL CREDITORS AND RURAL AND UNDERSERVED AREAS
On January 29, 2015 the Consumer Financial Protection Bureau (CFPB) proposed several changes to Regulation Z that impact small creditors, particularly in rural and underserved areas. The proposal would increase the number of financial institutions able to offer certain types of Qualified Mortgages (QM) in rural and underserved areas. Ability -to-Repay rules, which took effect in January 2014, require lenders to make a reasonable and good-faith determination that prospective borrowers have the ability to repay […]
FINAL RULE REVISES TIL AND RESPA
On January 18, 2015 the Consumer Financial Protection Bureau (CFPB) approved final changes to Regulations X and Z. The changes are effective on August 1, 2015. The final rule: Extends the timing requirement for revised disclosures when consumers lock a rate or extend a rate lock after the Loan Estimate is provided; Clarifies placement of the Nationwide Mortgage Licensing System and Registry ID (NMLSR ID) on the integrated disclosures; Permits certain language related to construction […]
2015 LENDING COMPLIANCE THRESHOLDS
Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2105 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion. The term “intermediate small bank” means a small […]