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On January 13, 2021, the Illinois legislature passed SB 1792, that, among other things, overhauls the state’s consumer finance laws through the provisions of the “Predatory Loan Prevention Ac.t” SB 1792 would extend the 36% “all-in” Military Annual Percentage Rate (MAPR) finance charge cap of the federal Military Lending Act (MLA) to “any person or entity that offers or makes a loan to a consumer in Illinois” unless made by a statutorily exempt entity (i.e., […]

Rest up and get ready to enjoy what will be a very busy compliance new year.

The Office of the Comptroller of the Currency (OCC) has published a final rule announcing changes to the maximum amount of each civil money penalty (CMP), for national banks and Federal savings associations, to account for inflation pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990 as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. The adjustments serve to maintain the deterrent effect of civil penalties and to […]

Is has been a truly weird year and as we approach the end of 2020 all of us at Compliance Resource wish you, and all those you love, a weird but extremely happy holiday season! Find a little joy and share it.

For 2021, the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in the asset size threshold for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a higher-priced mortgage loan (HPML). The exemption threshold is adjusted to increase to $2.230 billion from $2.202 billion. Creditors with assets of less than $2.230 billion (including assets of certain affiliates) […]