The emphasis on Unfair, Deceptive and Abusive Acts or Practices (UDAAP) is increasing. Violations are being cited with increasing frequency. The civil monetary penalties being imposed are substantial. While all of the federal regulatory agencies focus on the issue, the most intense focus seems to come from the Federal Deposit Insurance Corporation (FDIC). While all of the FDIC’s regions appear to be focusing on the issue, the most intense focus appears to be coming from […]
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HAPPY THANKSGIVING!
The Roman philosopher Seneca is credited with stating, “Nothing is more honorable than a grateful heart.” Since I always seek to be honorable, let me express my gratitude for all of you who have helped make this blog a success. You have provided us with over 20,000 visits to our blog in 2012. Thank you. If you need a dinner toast for today you may impress your friends and family with, “Here’s to the turkey […]
DOES THE CFPB REALLY WANT COMMENTS FROM COMMUNITY BANKERS?
The Consumer Financial Protection Bureau (CFPB) has cranked out more than 2,400 pages of new proposed regulations since July 9th. That is a lot to review in a short period of time. Let’s put this into context. The CFPB had two hours to draft each page starting from the date the Dodd-Frank Act became law. If you give the CFPB the benefit of the doubt and don’t start counting days until July 21, 2011, when […]
Proposed Regulation Z – Loan Originator Compensation
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PROPOSED REGULATION Z – LOAN ORIGINATOR COMPENSATION
On August 17, 2012 the Consumer Financial Protection Bureau (CFPB) released a 369-page proposal to amend Regulation Z. The amendments involve loan originator compensation. These proposals clarify and expand on existing regulations governing loan originator compensation and qualifications. They also implement new laws, including a restriction on the payment of upfront discount points, origination points, and fees on most mortgage loan transactions. Restriction on Upfront Points and/or Fees The proposed rule requires that, before a […]