On October 25, 2021, the Board of Governors of the Federal Reserve System issued Consumer Affairs Letter (CA 21-14) announcing revised Interagency Examination Procedures for Regulation Z. The comprehensive procedures are 384 pages in length. The revised procedures reflect amendments to Regulation Z published by the Consumer Financial Protection Bureau in 2020 and 2021: Implementing permanent changes to Regulation Z’s qualified mortgage provisions, and Implementing an extension and phase-out for the GSE Patch, which had […]
Tag: Truth in Lending
TRID AND THE END OF DAYLIGHT SAVING TIME
Daylight Saving Time (DT) ends on November 7, 2021 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 DT need to remember to change the […]
ADDITIONAL CFPB GUIDANCE ON JUNETEENTH
On August 5, 2021, the CFPB released an interpretive rule to assist the mortgage industry in determining whether to treat June 19, 2021, as a federal holiday or a business day for purposes of compliance with certain time-sensitive borrower protections. Regulation Z establishes timing requirements, calculated in business days, for when borrowers must receive certain disclosures and when borrowers have the right to cancel some mortgages. Because the Juneteenth National Independence Day Act was signed into […]
IMMEDIATE IMPACT OF THE JUNETEENTH BILL
On June 17, 2021, President Biden signed a bill that creates the Juneteenth National Independence Day. The bill amends 5 U.S.C. 6103(a) to add “Juneteenth National Independence Day, June 19” as a specified legal public holiday. This action impacts the definition of “business day,” as defined in Section 1026.2 of Regulation Z. Under TILA and Regulation Z, there are two definitions of “business day.” The general rule definition is “a day on which the creditor’s […]
CFPB FINALIZES DELAY OF RECENT QM RULES
On April 27, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule extending the mandatory compliance date of the General Qualified Mortgage (QM) Final Rule from July 1, 2021 to October 1, 2022. Additionally, the April 2021 Final Rule affects the expiration of the Temporary GSE QM loan definition or “Patch.” Under the April 2021 Final Rule, the Temporary GSE QM loan definition will expire on October 1, 2022 or the date the […]