Effective on January 10, 2014 § 1026.20 of Regulation Z requires that when a rate change accompanied by a payment change occurs on an ARM a notice must be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due (§ 1026.20(c)). An additional notice is required in connection with the initial interest rate adjustment provided to consumers. That notice must be provided at least […]
Tag: Lending Compliance
PROPOSED FLOOD REGULATIONS
Recently the Office of the Comptroller of the Currency, the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Farm Credit Administration, the National Credit Union Administration (jointly referred to as the Agencies) issued 166 pages of proposed rules for loans in areas having special flood hazards. The revisions to existing rules are based on changes from the Biggert-Waters Flood Insurance Reform Act of 2012. Comments are being accepted until December 10, 2013. The Agencies […]
2012 HMDA DATA
Earlier this week the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on mortgage lending transactions at 7,400 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). The HMDA data covers 2012 lending activity — applications, originations, purchases and sales of loans, denials, and other actions related to applications. The data include disclosure statements for each financial institution, aggregate data for each metropolitan statistical area (MSA), nationwide summary statistics regarding […]
MORE FINAL REVISED RULES – REGULATIONS B, X, AND Z
On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]
REGULATION E CIVIL MONETARY PENALTIES
Case 1 – In late July an Indiana bank was assessed a $70,000 penalty for engaging in unfair and deceptive acts or practices by the imposition of requirements on consumers in the resolution of electronic transfer errors which were more onerous than those set forth in Regulation E, thereby effectively delaying, denying or discouraging error resolution claims. Case 2 – In mid-July a bank located in Kentucky was assessed a $100,000 penalty for engaging in unfair […]