Archive

CARES ACT IMPACT ON CREDIT REPORTING

The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) became law on March 27, 2020. On April 1, 2020 the Consumer Financial Protection Bureau (CFPB issued a statement of policy on Supervisory and Enforcement Practices Regarding the Fair Credit Reporting Act and Regulation V in Light of the CARES Act. The statement highlights furnishers’ responsibilities under the CARES Act and inform consumer reporting agencies and furnishers of the CFPB’s flexible supervisory and enforcement approach […]

CFPB EXPANDS HMDA FAQS

On March 6, 2020 the Consumer Financial Protection Bureau added a new question and answer to its Home Mortgage Disclosure Act FAQs. The new Question 7. appears under the heading Ethnicity, Race, and Sex and § 1003.4(a)(10)(i) Question:  If a natural person applicant submits a mail, internet, or telephone application under Regulation C but does not provide race, ethnicity, or sex information, what should the financial institution report regarding whether this information was collected on […]

TRID FAQS EXPANDED FOR LENDER CREDITS

On February 26, 2020 the Consumer Financial Protection Bureau expanded its list of TRID Frequently Asked Questions to include 10 questions and answers related to Lender Credits. A copy, in Word format, of the FAQs is available, for no charge, at https://mycomplianceresource.com/product/trid-faqs-on-lender-credits-2/

FDCPA – PROPOSED REVISION TO THE PROPOSED REVISION

On February 13, 2020 the Consumer Financial Protection Bureau (CFPB) published a supplemental notice of proposed rulemaking (NPRM) dealing with the Fair Debt Collection Practices Act and Regulation F. The NPRM supplements the May 2019 Proposed Rule by proposing to require debt collectors to make certain disclosures when collecting time-barred debts. The CFPB proposes to prohibit collectors from using non-litigation means (such as calls) to collect on time-barred debt unless collectors disclose to consumers during […]

TRID AND DAYLIGHT SAVING TIME

Daylight Saving Time (DT) begins on Sunday March 8, 2020 at 2:00 a.m. It ends on November 1, 2020 at 2:00 a.m. What does DT 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 result, financial institutions located in […]