On October 25, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z and its Official Interpretations. The final rule revises the dollar amounts for provisions implementing TILA and amendments to TILA, including under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The CFPB is […]
Category: Truth in Lending
REVISED REGULATION Z EXAMINATION PROCEDURES
On October 25, 2021, the Board of Governors of the Federal Reserve System issued Consumer Affairs Letter (CA 21-14) announcing revised Interagency Examination Procedures for Regulation Z. The comprehensive procedures are 384 pages in length. The revised procedures reflect amendments to Regulation Z published by the Consumer Financial Protection Bureau in 2020 and 2021: Implementing permanent changes to Regulation Z’s qualified mortgage provisions, and Implementing an extension and phase-out for the GSE Patch, which had […]
TRID AND THE END OF DAYLIGHT SAVING TIME
Daylight Saving Time (DT) ends on November 7, 2021 at 2:00 a.m. What does DST 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 areas that observe DT need to remember to change the […]
ADDITIONAL CFPB GUIDANCE ON JUNETEENTH
On August 5, 2021, the CFPB released an interpretive rule to assist the mortgage industry in determining whether to treat June 19, 2021, as a federal holiday or a business day for purposes of compliance with certain time-sensitive borrower protections. Regulation Z establishes timing requirements, calculated in business days, for when borrowers must receive certain disclosures and when borrowers have the right to cancel some mortgages. Because the Juneteenth National Independence Day Act was signed into […]
IMMEDIATE IMPACT OF THE JUNETEENTH BILL
On June 17, 2021, President Biden signed a bill that creates the Juneteenth National Independence Day. The bill amends 5 U.S.C. 6103(a) to add “Juneteenth National Independence Day, June 19” as a specified legal public holiday. This action impacts the definition of “business day,” as defined in Section 1026.2 of Regulation Z. Under TILA and Regulation Z, there are two definitions of “business day.” The general rule definition is “a day on which the creditor’s […]