Archive

LAST MINUTE REVISIONS TO REGULATION Z SERVICING RULES

On March 6, 2018 the Consumer Financial Protection Bureau (CFPB) issued a final rule to help mortgage servicers communicate with certain borrowers facing bankruptcy. The revisions to Regulation Z give mortgage servicers more latitude in providing periodic statements to consumers entering or exiting bankruptcy, as required by the Bureau’s 2016 mortgage servicing rule. The 2016 mortgage servicing rule requires that servicers send modified periodic statements or coupon books to certain consumers in bankruptcy starting April 19, 2018. […]

HMDA GETTING IT RIGHT IS BACK

The Federal Financial Institutions Examination Council (FFIEC) has released an updated and expanded version of the publication A Guide to HMDA Reporting – Getting it Right (aka the HMDA bible). The publication had not been updated since 2013. The 327-page 2018 Guide is updated for the revisions to the Consumer Financial Protection Bureau’s (CFPB) Regulation C, which implements the Home Mortgage Disclosure Act (HMDA) that were effective January 1, 2018. The Guide includes the  revised […]

HURRICANE MARIA AND CRA CONSIDERATIONS

On January 25, 2018 the federal bank regulatory agencies (Federal Reserve Board, FDIC, OCC) announced they will give favorable consideration under Community Reinvestment Act (CRA) regulations to institutions that are located outside of the U.S. Virgin Islands and Puerto Rico, which were designated as major disaster areas in the aftermath of Hurricane Maria, for bank activities that help to revitalize or stabilize these areas. The CRA encourages financial institutions to help meet local credit and […]

CFPB STATEMENT ON PAYDAY RULE

On January 16, 2018 the Consumer Financial Protection Bureau (CFPB) issued the following statement on the Payday Rule: “January 16, 2018 is the effective date of the Bureau of Consumer Financial Protection’s final rule entitled “Payday, Vehicle Title, and Certain High-Cost Installment Loans” (“Payday Rule”).  The Bureau intends to engage in a rulemaking process so that the Bureau may reconsider the Payday Rule. Although most provisions of the Payday Rule do not require compliance until August […]

DISCOUNT POINTS

On November 28, the Federal Reserve Board (FRB) issued a consent order against Peoples Bank (Peoples), Lawrence, Kansas, for deceptive residential mortgage origination practices in violation of section 5 of the Federal Trade Commission Act. Apparently Peoples told certain borrowers that they were paying an additional amount for discount points that would lower the borrowers’ interest rate. In fact, many borrowers did not receive a reduced rate. The consent order requires Peoples to pay approximately […]