On December 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, ‘‘What You Should Know about Home Equity Lines of Credit,’’ also known as the HELOC booklet, required by the Truth in Lending Act (TILA), as implemented by Regulation Z. The CFPB is updating the HELOC booklet so that it aligns with the CFPB’s educational efforts, to be more concise, and to improve readability and usability. New features […]
Tag: Regulation Z
$6 MILLION PENALTY FOR REGULATION Z VIOLATIONS
On September 27, 2022, the Office of the Comptroller of the Currency imposed a $6 million penalty on Sterling Bank and Trust of Southfield, MI for engaging in unsafe and unsound banking practices, including violations of the Truth in Lending Act and Regulation Z. Between approximately mid-2011 and December 2019, the Bank: Offered the Advantage Loan Program (“ALP”), a low-document mortgage loan program, which was the Bank’s primary loan product during this period. The Bank […]
DAYLIGHT SAVING TIME TRID REMINDER
Daylight Saving Time (DST) ends on November 6, 2022 at 2:00 a.m. What does DST 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 areas that observe DST need to remember to change the […]
CFPB FACTSHEET – APR CALCULATION FOR GENERAL QM
On February 23, 2022, the Consumer Financial Protection Bureau (CFPB) published Factsheet: Prepaid Interest and the General Qualified Mortgage APR Special Rule for Adjustable Rate Mortgages. Creditors that wish to make qualified mortgages (QMs) under the price-based General QM definition must calculate the annual percentage rate (APR) for loans to determine whether they satisfy the price-based General QM definition. The priced-based General QM definition contains a special rule for calculating the APR for loans where […]
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DST) begins on Sunday March 13, 2022 at 2:00 a.m. It ends on November 6, 2022 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 […]