Archive

DISCOUNT POINTS

On November 28, the Federal Reserve Board (FRB) issued a consent order against Peoples Bank (Peoples), Lawrence, Kansas, for deceptive residential mortgage origination practices in violation of section 5 of the Federal Trade Commission Act. Apparently Peoples told certain borrowers that they were paying an additional amount for discount points that would lower the borrowers’ interest rate. In fact, many borrowers did not receive a reduced rate. The consent order requires Peoples to pay approximately […]

ADDITIONAL ANNUAL LENDING THRESHOLDS PUBLISHED

On November 9 the Consumer Financial Protection Bureau published additional 2018 lending compliance thresholds as follows: The HPML Appraisal Exemption Threshold contained in 1026.35(c)(2)(ii) increased from $25,500 to $26,000; and The Regulation Z Scope Thresholds contained in 1026.3(b)(1) increased from $54,600 to $55,800. The same threshold is applicable to Regulation M. Information regarding other TILA thresholds that were published in July is available at https://mycomplianceresource.com/annual-update-to-tila-dollar-amounts/ In a few weeks the remaining thresholds will be published. […]

SET YOUR CLOCKS BACK AND CHECK YOUR TRID DISCLOSURES

It’s that time of year again. Daylight Saving Time, or Daylight Time (DT), ends on November 5, 2017 at 2:00 a.m. If your financial institution is in an area that observes Daylight Savings Time, ensure the time zone designation has been updated to reflect Standard Time (ST) on your TRID disclosures. Under the TRID rules in Regulation Z creditors must disclose the date and time (including the applicable time zone): When the interest rate lock […]

ANNUAL UPDATE TO TILA DOLLAR AMOUNTS

On July 25, 2017 the Consumer Financial Protection Bureau (CFPB) approved a final rule that amends various dollar amounts that impact requirements of the Truth in Lending and Act and Regulation Z. The rule was published on August 30, 2017. This is an annual event. The revised amounts are effective on January 1, 2018. Be sure to update your procedures and systems to reflect the revised amounts as of the effective date. The revised amounts: For […]

TRID AMENDMENTS PUBLISHED

We reported on July 7, 2013 that the Consumer Financial Protection Bureau (CFPB) had released significant revisions to the TRI Rules. Now the revisions have been published in the Federal Register. Amendments are effective 60 days after the date of publication in the Federal Register with a mandatory compliance date of October 1, 2018. So with today’s publication the revisions are effective on October 10, 2017. This will allow financial institutions, in short order, to […]