Archive

2023 Modified HMDA LARs Released

Earlier this week, the CFPB Released the 2023 Modified HMDA loan/application registers (LARs). The HMDA modified LARs are now available for each institution that filed HMDA data collected in 2023. Institutions can find the data on the Federal Financial Institutions Examination Council’s (FFIEC) HMDA Platform for approximately 5,089 HMDA filers. The published data contains mortgage loan-level information for 2023 as modified to protect applicant and borrower privacy in accordance with the Consumer Financial Protection Bureau’s […]

Daylight Saving Time 2024 and TRID

REMINDER: Daylight Saving Time (DT) begins on Sunday March 10, 2024 at 2:00 a.m. It ends on November 3, 2024. But you may be wondering, what does Daylight Saving Time 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 […]

Section 1071: Where We Stand Now

Since Section 1071 of the Dodd-Frank act was finalized by the CFPB on March 30, 2023, it has been surrounded by controversy. The rule, requiring small business lenders to collect race, gender, and other demographic data from small business loan applicants, was more than a decade in the making but with various legal actions complicating the picture, let’s take a look at where Section 1071 stands now. Controversy in Congress Earlier this month, the Senate […]

The CFPB’s New Overdraft Fee Proposal

On January 17, 2024, the CFPB proposed a 211-page rule to limit overdraft fees charged by the nation’s biggest financial institutions. The proposal is intended to close what the CFPB calls a loophole that exempts overdraft lending services from longstanding provisions of the Truth in Lending Act and other consumer financial protection laws. The CFPB stated that very large financial institutions have been issuing highly profitable overdraft loans, resulting in billions of dollars in revenue […]

CFPB Piloting Disclosures for Construction Loans

Last week, the CFPB announced its approval of an application piloting disclosures for construction loans. In this initiative, the CFPB establishes guidelines for testing alternative disclosures in real-market scenarios, recognizing the enhanced accuracy of such tests compared to lab-based evaluations. The CFPB stated that testing in-market would allow them to gauge the potential necessity more accurately for regulatory adjustments. In short, lenders can now apply to test modified origination disclosures for construction loans to improve […]