On June 4, 2020 the Consumer Financial Protection Bureau (CFPB) published a 219 page proposal to amend Regulation Z to facilitate creditors’ transition away from using the London Interbank Offered Rate (LIBOR) as an index for variable-rate consumer credit products. The CFPB is proposing changes to: Certain open-end and closed-end provisions to provide examples of replacement indices for LIBOR indices that meet certain Regulation Z standards. Certain open-end provisions restricting index changes, requiring change-in-terms notices, […]
Tag: CFPB
RECENT TRID GUIDANCE – FACTSHEET AND FAQS
On June 9 the Consumer Financial Protection Bureau (CFPB) published a nine-page booklet entitled Factsheet: TRID Title Insurance Disclosures. The factsheet clarifies the disclosures for both Lender and Owner’s Title Insurance, including the disclosure of a simultaneous issuance. Several helpful examples are included. On June 9 the CFPB also published three new Frequently Asked Questions (FAQs). The new FAQs explain: Seller-Paid Loan Costs and Other Costs on Separate Closing Disclosures to the Seller and the […]
REVISED CHARM BOOKLET
On June 9,2020 the Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, the Consumer Handbook on Adjustable Rate Mortgages booklet, also known as the CHARM booklet, required under the Real Estate Settlement Procedures Act (RESPA) implemented by Regulation X and the Truth in Lending Act (TILA) implemented by Regulation Z. New features include: A comparison table that describes adjustable rate mortgages and their differences in relation to fixed-rate loan products; […]
CFPB FAQS FOR OPEN-END CREDIT AND COVID-19
On May 13 the Consumer Financial Protection Bureau (CFPB) published three Frequently Asked Questions (FAQs) regarding open-end (not home-secured) rules related to the COVID-19 pandemic. The FAQs are “compliance aids,” which do not have the weight of the law or the regulations. The first FAQ addresses changes to account terms. The answer indicates that a creditor may change terms on an open-end account, although most significant changes in terms require advance notice. It clarifies that […]
REGULATION B – CLARIFICATION FOR PPP LOANS
On May 6 the Consumer Financial Protection Bureau (CFPB) issued three clarifying Frequently Asked Questions ( FAQs) to support small businesses who have applied for a loan from their financial institution under the Small Business Administration’s (SBA) Paycheck Protection Program (PPP). Question 1. – Creditors are generally required under the Equal Credit Opportunity Act and Regulation B to notify applicants within 30 days of receiving a “completed application” of the creditor’s approval, counteroffer, denial or […]