Last week, the FDIC provided the industry with a Financial Institution Letter (FIL 43-2015) to detail what financial institutions can expect in terms of initial examinations after the October 3rd TRID implementation date. The first blog article in this series regarding TRID exam expectations can be found here. The Financial Institution Letter came after the CFPB released in mid-September the updated examination procedures the Bureau will rely on to complete initial exams. In July, Director […]
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NEW REGULATION Z RULES FOR SMALL LENDERS AND RURAL AND UNDERSERVED AREAS
On September 21, 2015 the Consumer Financial Protection Bureau approved a final rule amending Regulation Z. The final rule revises the CFPB’s regulatory definitions of small creditor, and rural and underserved areas, for purposes of certain special provisions and exemptions from various requirements provided to certain small creditors under the Bureau’s mortgage rules. The final rule specifically addresses: Escrow requirements for higher-priced mortgage loans; Ability-to-repay/qualified mortgage requirements; and HOEPA requirements. Small Creditor – Loan Volume […]
ABA RCC – FEAR IN THE AIR
Over the years it has become apparent that standing room only (SRO) crowds for a particular session at the ABA RCC means either: The ABA misjudged the popularity of the topic and assigned it to an undersized room; or There is a sense of fear in the air. The “fear in the air” SRO topics so far this year include: TRID; HMDA; and Flood Insurance. HMDA and Flood represent fear of the unknown and these […]
LIFE ON THE ROAD – TIGERNADO
Life on the road often brings surprises, last week more so than usual. On Wednesday evening I was travelling from a seminar in Tulsa to Oklahoma City. It was a race to see who or what would arrive first – our car or the storm. The car finished first That evening the Oklahoma City area was hit be more than a dozen tornadoes. I tried to keep up with the breaking weather news as I sat […]
SUCCESS STORY
I got a call from one of my Compliance Master Group (CMG) members yesterday. I hear from her occasionally. She was confirming that she had reached the correct conclusion on an issue that she had researched. It hasn’t always worked that way. Years ago she called very frequently with basic questions; she didn’t have a clue where to find the answers. After we discussed her issue yesterday she shared with me that they had just […]