Archive

UPDATED TRID GUIDANCE

On July 31, the Consumer Financial Protection Bureau updated its TILA-RESPA Integrated Disclosure FAQs by adding five questions related to providing loan estimates to consumers: The questions include: When is a creditor required to provide a loan estimate to a consumer? Can creditors require consumers to provide additional information (other than the six pieces of information constituting an application) in order to receive a loan estimate? Can creditors require consumers to submit verifying documents before they […]

QM Changes Considered

On July 25 the Consumer Financial Protection Bureau (CFPB) published a 30-page Advance Notice of Proposed Rulemaking (ANPR) seeking comments relating to the scheduled January 10, 2021, expiration of the temporary qualified mortgage provision applicable to loans eligible for purchase or guarantee by the Government Sponsored Enterprises, Fannie Mae and Freddie Mac. That provision is in the CFPB’s Ability to Repay/Qualified Mortgage (ATR/QM) Rule (section 1026.43 of Regulation Z).   The Bureau is considering whether […]

Equifax Penalties – Delayed Justice

On July 22, 2019 the Federal Trade Commission (FTC) announced that Equifax Inc. has agreed to pay at least $575 million, and potentially up to $700 million, as part of a global settlement with the FTC, the Consumer Financial Protection Bureau (CFPB), and 50 U.S. states and territories, which alleged that the credit reporting company’s failure to take reasonable steps to secure its network led to a data breach in 2017 that affected approximately 147 […]

PROPOSED DEBT COLLECTION RULE

On May 7, 2019 the Consumer Financial Protection Bureau (CFPB) issued a proposed rule, contained in Regulation F, to implement the Fair Debt Collection Practices Act (FDCPA). The proposal establishes clear limits on the number of calls debt collectors may place to reach consumers on a weekly basis; clarifies how collectors may communicate lawfully using newer technologies, such as voicemail, email and text messages, that have developed since the FDCPA’s passage in 1977; and requires […]