On February 27, 2023, the Consumer Financial Protection Bureau (CFPB) published a blog article regarding efforts by the Independent Community Bankers of America (ICBA) to gain approval for an application regarding consumer disclosures of a loan that provides either construction or construction-permanent financing In its April 28, 2022 application, the ICBA states it is not uncommon in rural communities for first-time homebuyers to build their first home because there are limited existing affordable “starter” homes. The […]
Category: Truth in Lending
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DT) begins on Sunday March 12, 2023 at 2:00 a.m. It ends on November 5, 2023 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 […]
HAPPY HOLIDAYS AND A THRESHOLD UPDATE
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 […]
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 […]