Recently the Consumer Financial Protection Bureau (CFPB) published its most recent semiannual rulemaking agenda. There were no big surprises in the agenda. This article reviews three issues of concern. Integrated Disclosures and Finance Charge Rules – The biggest rules yet to be finalized are the new integrated disclosures. The disclosures include the loan estimate (that combines the early TIL disclosure and the good faith estimate) and the closing disclosure (that combines the final TIL disclosures […]
Tag: Regulation B
CFPB PROPOSES CHANGES TO REGULATIONS B, X, AND Z
On June 24, 2013 the Consumer Financial Protection Bureau published proposed changes to several final rules originally published in January 2013. The proposal would: Provide procedures for obtaining follow-up information on loss-mitigation applications; Make it easier for servicers to offer short-term forbearance plans; Revise the definitions of “rural” and “underserved” and provide interim rules until the revised definitions are complete; Provide clarification about financing credit insurance; Clarify the definition of “loan originator;” Clarify the definition […]
INDIRECT AUTO FINANCING – FAIR LENDING CONCERNS
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 […]
BUSINESS DAY – NEW REGULATION B APPRAISAL RULES
The appraisal rules contained in Regulation B were revised on January 18, 2013. The revisions are effective on January 18, 2014. Among other requirements, the revised regulation requires that: A copy of each appraisal or other written evaluation be provided to the applicant three business days prior to consummation; Not later than the third business day after the creditor receives the application it must provide the applicant with a notice regarding the right to receive […]
CFPB PUBLISHES NEW REGULATION B APPRAISAL RULES
On January 18, 2013 the Consumer Financial Protection Bureau published a124-page final rule to amend Regulation B, which implements the Equal Credit Opportunity Act. The final rule revises rules for appraisals and other valuations that was enacted as part of the Dodd-Frank Act. The final rule is effective on January 18, 2014. For applications for credit secured by a first lien on a dwelling the new rule: Requires creditors to notify applicants within three business […]