Archive

DON’T FORGET JUNETEENTH

On June 17, 2021, the President signed legislation that amended 5 U.S.C. 6103(a) to add “Juneteenth National Independence Day, June 19” (Juneteenth) to the list of Federal legal public holidays (Federal holidays). Various regulatory provisions cross-reference or otherwise refer to the Federal holidays listed in 5 U.S.C. 6103(a), including the Regulation Z definition of “business day.” In Regulation Z, “business day” is defined in § 1026.2(a)(6) generally to mean “a day on which the creditor’s […]

CFPB FACTSHEET – APR CALCULATION FOR GENERAL QM

On February 23, 2022, the Consumer Financial Protection Bureau (CFPB) published Factsheet: Prepaid Interest and the General Qualified Mortgage APR Special Rule for Adjustable Rate Mortgages. Creditors that wish to make qualified mortgages (QMs) under the price-based General QM definition must calculate the annual percentage rate (APR) for loans to determine whether they satisfy the price-based General QM definition. The priced-based General QM definition contains a special rule for calculating the APR for loans where […]

TRID AND DAYLIGHT SAVING TIME

Daylight Saving Time (DST) begins on Sunday March 13, 2022 at 2:00 a.m. It ends on November 6, 2022 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 2022 LENDING THRESHOLDS PUBLISHED

On December 23, 2022, the Consumer Financial Protection Bureau (CFPB) published the final 2022 lending thresholds. The CFPB published a final rule amending Regulation C to reflect the asset-size exemption threshold for banks, savings associations, and credit unions based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). Based on the 4.7 percent increase in the average of the CPI-W for the 12-month […]

FINAL REGULATION Z RULES FOR LIBOR

On December 8, 2021 the Consumer Financial Protection Bureau (CFPB) amended Regulation Z, which implements the Truth in Lending Act (TILA), generally to address the anticipated sunset of LIBOR, which is expected to be discontinued for most U.S. Dollar (USD) tenors in June 2023. Some creditors currently use USD LIBOR as an index for calculating rates for open-end and closed-end products. The CFPB is amending: The open-end and closed-end provisions to provide examples of replacement […]