2017 was a busy year for compliance. It looks like 2018 is lining up to be another big year as we complete implementation of HMDA, TRID revisions, and numerous other projects. In my 42-year career I have seen the pendulum swing from one extreme to another several times. Since the mortgage crisis 10 years ago we have been plagued with a huge volume of new and revised compliance laws and regulations. With the current administration […]
Month: December 2017
CFPB LAUNCHES ADDITIONAL HMDA TOOLS
On December 27, 2017 the Consumer Financial Protection Bureau(CFPB) launched its HMDA Check Digit Tool and Rate Spread Calculator. These tools, or similar tools, are needed to assure compliance with new HMDA data collection rules that are effective on January 1.2018. HMDA Check Digit Tool – The Check Digit Tool: Generates a two character check digit when you enter a Legal Entity Identifier (LEI) and loan or application ID; and Validates that a check digit […]
CFPB SHIFTS ITS MISSION
One of the two Acting Directors of the Consumer Financial Protection Bureau (CFPB) is quietly putting his stamp on the agency. Mr. Mulvaney is changing small details like the tag line that appears on CFPB press releases. Before Mr. Mulvaney showed up the tag line read, “The Consumer Financial Protection Bureau is a 21st century agency that helps consumer finance markets work by making rules more effective, by consistently and fairly enforcing those rules, and […]
FINAL 2018 LENDING THRESHOLDS
Each year more than a half dozen lending thresholds are published by the federal regulators from mid-summer to the last days of the year.. The thresholds determine coverage for various requirements in the Home Mortgage Disclosure Act, the Truth in Lending Act and the Community Reinvestment Act. On December 27, 2017 the Consumer Financial Protection Bureau (CFPB) published the final lending thresholds for 2017. The HMDA asset-size exemption threshold was increased from $44 million to […]
LATE YEAR SERVICEMEMBER REVISIONS
Laws that impact lending to servicemembers include the Military Lending Act and the Servicemembers Civil Relief Act. Both laws have been recently amended. Both sets of amendments bring clarity to areas of uncertainty. In response to these recent changes all creditors need to update their compliance management systems. Changes to policies, procedures, audit and training are needed to assure continued compliance. The revisions are already effective. Servicemembers Civil Relief Act (SCRA) On December 12, 2017 […]