On May 13 the Consumer Financial Protection Bureau (CFPB) published a Statement on Supervisory and Enforcement Practices Regarding Regulation Z Billing Error Resolution Timeframes in Light of the COVID-19 Pandemic (the statement). The Truth in Lending Act generally requires that creditors investigate and resolve consumers’ billing error notices within specified maximum timeframes. Good news – The statement provides notice to creditors that the CFPB intends to take a flexible supervisory and enforcement approach with respect […]
Category: Truth in Lending
CORONA RELIEF – ECOA VALUATION RULE
On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]
CORONA RELIEF – TRID AND RESCISSION WAITING PERIODS
On April 28 the Consumer Financial Protection Bureau (CFPB) released an Interpretative Rule that concludes that a consumer has a “bona fide personal financial emergency” if the consumer determines that his or her need to obtain funds due to the COVID-19 pandemic Necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or Must be met before the end of the Regulation Z Rescission Rules waiting period. Under such circumstances the […]
FFIEC ANNOUNCES NEW APR AND APY COMPUTATIONAL TOOLS
On April 16, 2020 the Federal Financial Institutions Examination Council (FFIEC) announced the availability of FFIEC Federal Disclosure Computational Tools, including the Annual Percentage Rate (APR) Computational Tool and the Annual Percentage Yield (APY) Computational Tool. The FFIEC member agencies collaborated to develop the Federal Disclosure Computational Tools, which will assist financial institutions in their efforts to comply with the consumer protection laws and regulations. The APR Computational Tool is designed to streamline the process […]
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DT) begins on Sunday March 8, 2020 at 2:00 a.m. It ends on November 1, 2020 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 […]