The CFPB is assisting the Department of Education with creating a “financial aid shopping sheet” that colleges could use to improve information for students and their families. The draft shopping sheet is posted on the CFPB website, where comments from students, families, and other stakeholders are sought. It includes estimated monthly payments after leaving school and helpful school-related information such as graduation rates. And, importantly, it allows students to compare an offer from one school […]
Category: Truth in Lending
REGULATION Z – LOAN ORIGINATOR COMPENSATION RULES
Everyone seems aware that Regulation Z rules, which were effective on April 1, 2011, state that no loan originator shall receive and no person shall pay to a loan originator, directly or indirectly, compensation in an amount that is based on any of the transaction’s terms or conditions. Everyone also seems aware that the term “compensation” includes salaries, commissions, and any financial or similar incentive provided to a loan originator that is based on any […]
ABILITY TO REPAY – PROPOSED REGULATIONS
Recently the Federal Reserve Board (FRB) requested comment on a proposed rule under Regulation Z that requires creditors to determine a consumer’s ability to repay a mortgage before making the loan and also establishes minimum mortgage underwriting standards. We already have a similar requirement for Section 32 mortgages, Section 35 mortgages (higher-priced mortgage loans), and for open-end credit. The requirement is being expanded to all consumer mortgage loans (except home equity lines of credit, timeshare […]
New Regulation Z Dollar Threshold
On March 24, 2011 the Federal Reserve Board approved a change to Regulation Z that increases the threshold for transactions exempt from Regulation Z from $25,000 to $50,000. This change was mandated by the Dodd Frank Act. The change is effective on July 21, 2011. So you may be wondering – What are the details of this change? What does the change mean to my bank? DETAILS Currently, the Truth in Lending Act (TILA) exempts […]
REGULATION Z – NEW FINAL RULE INCREASES DOLLAR LIMIT ON COVERED TRANSACTIONS
On March 25th the Federal Reserve Board adopted a new rule that expands the coverage of Regulation Z to credit transactions of higher dollar amounts. The final rule amends Regulation Z to implement a provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Effective July 21, 2011, the Dodd-Frank Act requires that the protections of the Truth in Lending Act (TILA) apply to consumer credit transactions up to $50,000, compared with $25,000 currently. […]