Daylight Saving Time (DT) begins on March 12, 2017. What does that 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 areas that observe DT need to remember to change the time designation used […]
Tag: Lending Compliance
WORTH WATCHING – BOA DISCRIMINATION CASE
The U.S. Department of Housing and Urban Development (HUD) recently announced it has charged Bank of America, N.A., and two of its employees with violating the Fair Housing Act by discriminating against prospective Hispanic mortgage borrowers in Charleston, South Carolina. The National Fair Housing Alliance (NFHA) filed a complaint with HUD claiming the bank discriminated against prospective borrowers who are Hispanic by failing to provide them with information about loan products or by offering them […]
AGENCIES ANNOUNCE REVISED CRA THRESHOLDS
On December 29, 2016 the federal bank regulatory agencies announced the annual adjustment to the asset-size thresholds used to define small bank, small savings association, intermediate small bank, and intermediate small savings association under the Community Reinvestment Act (CRA) regulations. The annual adjustments are required by the CRA rules. Financial institutions are evaluated under different CRA examination procedures based upon their asset-size classification. Those meeting the small and intermediate small institution asset-size thresholds are not […]
LEP – THE NEXT BIG THING?
On September 15, 2016 the Department of Housing and Urban Development published guidance on Fair Housing Act Protections for Persons With Limited English Proficiency. The guidance applies to your role as a mortgage lender, and your role as a landlord, if applicable. Limited English Proficiency (LEP) refers to a person’s limited ability to read, write, speak, or understand English. Questionable practices include refusing to allow an LEP borrower to have mortgage documents translated, or refusing […]
REVISED SMALL ENTITY COMPLIANCE GUIDE FOR MORTGAGE SERVICING RULES
On November 30, 2016 the Consumer Financial Protection Bureau published an updated version of the Small Entity Compliance Guide entitled Real Estate Settlement Procedures Act (Regulation X) and Truth In Lending Act (Regulation Z) Mortgage Servicing Rules. The Guide is updated to reflect the August 2016 Final Rule that makes significant changes to the servicing rules contained in both regulations. The August 2016 Final Rule changes impact all financial institutions. The impact on small servicers […]