The final rule implementing Section 1071 of the Dodd-Frank Act is massive. There are a couple additional pieces of guidance that may offer relief to some institutions. The Consumer Financial Protection Bureau (CFPB) has provided a Filing Instructions Guide, a Small Business Lending rule: Data Points Chart, a Grace Period Policy Statement and a Statement on Enforcement and Supervisory Practices Relating to Small Business Lending Rule. Details follow. Filing Instructions Guide – The 2024 Filing […]
Tag: CFPB
JOINT APPLICATIONS AND FINAL SECTION 1071
The proposed regulation to implement section 1071 did not address the handling of joint applications. This writer and others commented on the lack of guidance for reporting joint applications. Joint applications for commercial and agricultural loans are not common, but they do occur. The issue is whether information is collected for each applicant, or for a single applicant, and if a single applicant, which applicant. The final regulation, published on March 30, includes comment 103(a)-10 […]
TRID DISCLOSURES FOR CONSTRUCTION LOANS – ARE REVISIONS POSSIBLE?
On February 27, 2023, the Consumer Financial Protection Bureau (CFPB) published a blog article regarding efforts by the Independent Community Bankers of America (ICBA) to gain approval for an application regarding consumer disclosures of a loan that provides either construction or construction-permanent financing In its April 28, 2022 application, the ICBA states it is not uncommon in rural communities for first-time homebuyers to build their first home because there are limited existing affordable “starter” homes. The […]
UPDATE ON APPRAISALS AND DISCRIMINATION
On February 14, 2023, the Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, U.S. Department of Housing and Urban Development, National Credit Union Administration, Federal Reserve Board, U.S. Department of Justice, Office of the Comptroller of the Currency, and the Federal Housing Finance Agency (the “agencies”) sent a joint letter to The Appraisal Foundation (TAF) expressing concerns with the Fourth Exposure Draft of Proposed Changes for the 2023 Edition of the Uniform Standards of Professional Appraisal Practice […]
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DT) begins on Sunday March 12, 2023 at 2:00 a.m. It ends on November 5, 2023 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 […]