On April 28 the Consumer Financial Protection Bureau (CFPB) released an Interpretative Rule that concludes that a consumer has a “bona fide personal financial emergency” if the consumer determines that his or her need to obtain funds due to the COVID-19 pandemic Necessitates consummating the credit transaction before the end of the TRID Rule waiting periods or Must be met before the end of the Regulation Z Rescission Rules waiting period. Under such circumstances the […]
Tag: TRID
TRID FAQS EXPANDED FOR LENDER CREDITS
On February 26, 2020 the Consumer Financial Protection Bureau expanded its list of TRID Frequently Asked Questions to include 10 questions and answers related to Lender Credits. A copy, in Word format, of the FAQs is available, for no charge, at https://mycomplianceresource.com/product/trid-faqs-on-lender-credits-2/
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DT) begins on Sunday March 8, 2020 at 2:00 a.m. It ends on November 1, 2020 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 […]
CFPB REGULATORY STATUS CHECK
On February 6, 2020 Kathleen Kraninger presented the Consumer Financial Protection Bureau’s (CFPB’s) Fall 2019 Semi-Annual Report to Congress, covering the period from .April 1, 2019, to September 30, 2019. The Report provides updates on a number of current regulatory efforts including, but not limited to: Payday, Vehicle Title, and Certain High-Cost Installment loans In February 2019, the CFPB released Notices of Proposed Rulemaking (NPRM) on the 2017 Payday, Vehicle Title, and Certain High-Cost Installment […]
DISCLOSURE OF GIFT EQUITY
Recently we received the following question in our Community Forum: Question: When the amount of gift equity is known at the time of initial disclosure, should the gift equity amount be disclosed on the Loan Estimate in the calculating cash to close section as a seller credit or adjustments and other credits? There does not appear to be any clear cut guidance in 1026.37(H)(1)(vi) or (vii). Thank you Answer: A gift of equity can take […]