Recently the Consumer Financial Protection Bureau (CFPB) published a bulletin (CFPB Bulletin 2013-02) that provides guidance on compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA) and Regulation B for indirect auto lenders. The bulletin addresses practices that permit dealers to increase consumer interest rates and to compensate dealers with a share of the increased interest revenues. This guidance applies to all indirect auto lenders, including both depository institutions and nonbank […]
Tag: Lending Compliance
PROPOSED REVISIONS TO INTERAGENCY CRA QUESTIONS AND ANSWERS
The Office of the Comptroller of the Currency, the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies) are proposing to clarify their Interagency Questions and Answers Regarding Community Reinvestment to address several community development issues. The Questions and Answers were first published under the auspices of the Federal Financial Institutions Examination Council (FFIEC) in 1996, and were last revised on March 11, 2010. The Agencies propose to: Revise five questions and answers, […]
CRIMINAL BACKGROUND CHECKS AND CREDIT REPORTS FOR LOAN ORIGINATORS
I have had a lot of questions regarding new loan originator qualification standards that take effect on January 10, 2014. On January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published revisions to Regulation Z that expand the SAFE Act requirements that apply to Loan Originators. It is odd that SAFE Act revisions end up in the Truth in Lending Act, but this not the most seriously odd thing that Congress has done lately. Section […]
CFPB PUBLISHES PRELIMINARY LIST OF RURAL AND UNDERSERVED COUNTIES
On March 12, 2013 the Consumer Financial Protection Bureau (CFPB) announced the availability of a preliminary list of rural and underserved counties. The final list will be available before June 1, 2013. The list has significant impact on several regulatory requirements, as follows: On June 1, 2013, the CFPB’s Escrow Requirements under the Truth in Lending Act rule (Escrows Rule) will go into effect, which require certain creditors to create escrow accounts for a minimum of 5 […]
AVAILABILITY OF THE CHARM BOOKLET
Many bankers have relied on the Federal Reserve Board (FRB) for years as an inexpensive source for the disclosure booklets required for adjustable-rate mortgages. The booklet is frequently referred to as the Consumer Handbook for Adjustable-Rate Mortgages, or CHARM Booklet. Recently it came to my attention that the CHARM Booklet is no longer available through the FRB’s website since the underlying regulation, Regulation Z, has been transferred to the Consumer Financial Protection Bureau (CFPB). However, […]