We have had several recent questions on this topic. What constitutes an application for TRID is very different from the concept of “application” for the purpose of providing an adverse action notice under Regulation B or reporting data under Regulation C. It would take a large book to thoroughly explore all the nuances of “applications” under federal laws. This article explores only a few basic concepts. Regulation Z Under Section 1026.2(a)(3)(ii), for transactions subject to […]
Tag: Regulation C
CHANCE TO BREATHE
I lot of people seemed to think that once the August 1 TRID deadline arrived life would be much easier. Well today is August 1, and the future doesn’t look any easier. TRID has been delayed until October 3, 2015; New interagency flood insurance regulations are effective, in large part, on October 1, 2015, with the new escrow rules unfolding on January 1, 2016; The new Military Lending Act regulations, which look like the real […]
2015 HMDA ISSUES
The January 2015 issue of the FFIEC’s CRA/HMDA Reporter has several good reminders about HMDA issues. The lead article, HOEPA Changes and New Edit Changes, focuses on changes to Regulation Z (HOEPA) rules that were effective in January 2014 and impacted the 2014 HMDA data just submitted by your bank. The changes lowered the rate spread threshold of HOEPA eligible loans, and expanded coverage to certain home purchase mortgage products. The Reporter is available by […]
2015 LENDING COMPLIANCE THRESHOLDS
Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2105 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion. The term “intermediate small bank” means a small […]
2013 HMDA DATA NOW AVAILABLE
On September 22, 2014 the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on mortgage lending transactions at 7,190 U.S. financial institutions covered by the Home Mortgage Disclosure Act (HMDA). Covered institutions include banks, savings associations, credit unions, and mortgage companies. The HMDA data cover 2013 lending activity, and include applications, originations, purchases and sales of loans, denials, and other actions related to applications. The data also include disclosure statements for […]