On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]
Tag: Lending Compliance
CORONA RELIEF – TRID AND RESCISSION WAITING PERIODS
On April 28 the Consumer Financial Protection Bureau (CFPB) released an Interpretative Rule that concludes that a consumer has a “bona fide personal financial emergency” if the consumer determines that his or her need to obtain funds due to the COVID-19 pandemic Necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or Must be met before the end of the Regulation Z Rescission Rules waiting period. Under such circumstances the […]
CRA PROPOSAL COMMENT PERIOD EXTENDED
On February 19,2020, the OCC and FDIC announced a 30-day extension of the comment period for the proposed changes for the CRA regulation. The new comment deadline will be April 8th.
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DT) begins on Sunday March 8, 2020 at 2:00 a.m. It ends on November 1, 2020 at 2:00 a.m. What does DT 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 […]
2020 HMDA GUIDE
On February 12, 2020 the Federal Financial Institutions Examination Council (FFIEC) published its 2020 version of A Guide to HMDA Reporting – Getting It Right. The Guide, which has been published since 1998, provides a summary of responsibilities and requirements, directions for assembling the necessary tools, and instructions for reporting HMDA data. The 2020 version is updated to include information from the final rule published by the CFPB in October 2019. Primarily, the 2020 Guide […]