Archive

FINAL THRESHOLD UPDATE FOR 2022

I bet you thought that you were all wrapped up on your compliance news for 2022, huh? Well…not so fast! On December 28, 2022, The CFPB released the final HMDA threshold and the remaining Regulation Z thresholds. The HMDA threshold was increased from $50 million in 2022 to $54 million in 2023. The HPML Small Creditor Threshold was increased from $2.336 billion to $2.537 billion in 2023. The HPML Intermediate Creditor Threshold was increased from […]

LIABILITY AFTER FORECLOSURE – THE SEQUEL

Last fall, we published a blog article that reviewed the intricacies of the “Liability after Foreclosure” disclosure.  Here we provide a quick update and add some valuable new information. As a refresher, the following disclosure appears in the Loan Estimate but only when the transaction is defined as a refinance: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses […]