Recently the Consumer Financial Protection Bureau (CFPB) finalized a revision to a 2011 rule on credit card fees. The 2009 Credit CARD Act (CARD Act) limited certain fees charged during the first year after the account is opened to 25 percent of the account’s initial credit limit. In April 2011, the Federal Reserve Board amended its rules implementing the CARD Act to extend this limitation to fees that the consumer must pay prior to opening […]
Category: Regulation Z
CRIMINAL BACKGROUND CHECKS AND CREDIT REPORTS FOR LOAN ORIGINATORS
I have had a lot of questions regarding new loan originator qualification standards that take effect on January 10, 2014. On January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published revisions to Regulation Z that expand the SAFE Act requirements that apply to Loan Originators. It is odd that SAFE Act revisions end up in the Truth in Lending Act, but this not the most seriously odd thing that Congress has done lately. Section […]
CFPB PUBLISHES PRELIMINARY LIST OF RURAL AND UNDERSERVED COUNTIES
On March 12, 2013 the Consumer Financial Protection Bureau (CFPB) announced the availability of a preliminary list of rural and underserved counties. The final list will be available before June 1, 2013. The list has significant impact on several regulatory requirements, as follows: On June 1, 2013, the CFPB’s Escrow Requirements under the Truth in Lending Act rule (Escrows Rule) will go into effect, which require certain creditors to create escrow accounts for a minimum of 5 […]
AVAILABILITY OF THE CHARM BOOKLET
Many bankers have relied on the Federal Reserve Board (FRB) for years as an inexpensive source for the disclosure booklets required for adjustable-rate mortgages. The booklet is frequently referred to as the Consumer Handbook for Adjustable-Rate Mortgages, or CHARM Booklet. Recently it came to my attention that the CHARM Booklet is no longer available through the FRB’s website since the underlying regulation, Regulation Z, has been transferred to the Consumer Financial Protection Bureau (CFPB). However, […]
FINAL LOAN ORIGINATOR COMPENSATION RULES NOW AVAILABLE
On Sunday January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z to revise and clarify existing regulations and commentary on loan originator compensation. The rules also implement Dodd-Frank Act provisions that prohibit certain arbitration agreements and the financing of certain credit insurance in connection with a mortgage loan. The 540-page final rule was published just hours before the Dodd-Frank mandated January 21, 2013 deadline. The rules take effect […]