On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]
Tag: Consumer Financial Protection Bureau
CORONA RELIEF – TRID AND RESCISSION WAITING PERIODS
On April 28 the Consumer Financial Protection Bureau (CFPB) released an Interpretative Rule that concludes that a consumer has a “bona fide personal financial emergency” if the consumer determines that his or her need to obtain funds due to the COVID-19 pandemic Necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or Must be met before the end of the Regulation Z Rescission Rules waiting period. Under such circumstances the […]
AGENCIES DEFER APPRAISALS
On April 14, 2020 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, National Credit Union Administration, and the Consumer Financial Protection Bureau (jointly, the agencies) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the interagency appraisal regulations. The agencies are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly […]
NEW HMDA REPORTING THRESHOLD
On April 16, 2020 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation C to set the thresholds for reporting data about: Closed-end mortgage loans, so that institutions originating fewer than 100 closed-end mortgage loans in either of the two preceding calendar years will not have to report such data effective July 1, 2020. Open-end lines of credit at 200 open-end lines of credit effective January 1, 2022, upon the expiration of […]
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 […]