Archive

I have always enjoyed fruit. When I was a kid we always had a selection of fruits in the house, and on rare occasions we had a more exotic fruit, like figs. Most of my family didn’t like figs, so my Mom and I always split them. They were quite a treat. I haven’t had any figs in a while, but soon we all will have more FIG than we want. Final revisions to Regulation […]

Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2016 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.216 billion. The term “intermediate small bank” means a small […]

Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements […]

We have had several recent questions on this topic. What constitutes an application for TRID is very different from the concept of “application” for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C. It would take a large book to thoroughly explore all the nuances of “applications” under federal laws. This article explores only a few basic concepts. Regulation Z Under Section 1026.2(a)(3)(ii), for transactions subject to […]

I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real […]