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 […]
Category: Truth in Lending
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 […]
AGENCIES INCREASE REGULATION M AND Z THRESHOLDS
On November 29, 2021 the Office of the Comptroller of the Currency, Treasury (OCC); Board of Governors of the Federal Reserve System (Board); and Bureau of Consumer Financial Protection (Bureau) announced new coverage thresholds for: Consumer Leasing (Regulation M) – Based on the annual percentage increase in the CPI-W as of June 1, 2021, the exemption threshold will increase from $58,300 to $61,000 effective January 1, 2022. Appraisal for Higher-Priced Mortgage Loans Exemption Threshold – […]