On June 17, 2021 the Federal Financial Institutions Examination Council (FFIEC) published 2020 HMDA data. The data is always a treasure trove. The following are a few quick observations about the data. For 2020, the number of reporting institutions declined by about 18.8 percent from the previous year to 4,475. One reason for the change is that, in 2020, the Bureau issued a final rule amending Regulation C to increase the threshold for collecting and […]
Tag: CFPB
CFPB CLARIFICATION ON JUNETEENTH
On June 18, 2021, the Consumer Financial Protection Bureau (CFPB) published the following statement: President Biden’s signing of the Juneteenth National Independence Day Act into law yesterday afternoon is a cause for celebration. Juneteenth is a moment for us to commemorate the emancipation of those enslaved. I am proud that we as a country are taking concrete steps to recognize and heal from the legacy of slavery, even as I recognize that there is much […]
IMMEDIATE IMPACT OF THE JUNETEENTH BILL
On June 17, 2021, President Biden signed a bill that creates the Juneteenth National Independence Day. The bill amends 5 U.S.C. 6103(a) to add “Juneteenth National Independence Day, June 19” as a specified legal public holiday. This action impacts the definition of “business day,” as defined in Section 1026.2 of Regulation Z. Under TILA and Regulation Z, there are two definitions of “business day.” The general rule definition is “a day on which the creditor’s […]
CFPB PUBLISHES EFT FAQS
On June 4, 2021, the Consumer Financial Protection Bureau published eight Electronic Fund Transfers FAQs. The Frequently Asked Questions address: Do fraudulent inducements constitute “unauthorized electronic fund transfer?” In a fraudulent inducement has a consumer furnished an access device under Regulation E? Can negligence by the consumer be used as the basis for imposing greater liability than is permissible under Regulation E.? Can an agreement restrict a consumer’s rights beyond what is provided in the […]
FIVE TRID FAQS ADDED
The Consumer Financial Protection Bureau has added five new questions and answers related to Housing Assistance Loans to the TILA-RESPA Integrated Disclosure FAQs. The new questions, which are effective immediately, cover: Are housing assistance loans covered by the TRID rule? What are the criteria for the Regulation Z Partial exemption from the Loan Estimate and Closing Disclosure Requirements? What are the criteria for the BUILD Act Partial Exemption from the Loan Estimate and Closing Disclosure […]