On April 29, 2020 the Consumer Financial Protection Bureau (CFPB) published a Compliance Aid dealing with the ECOA Valuation Rule. The Aid, which is in Question/Answer format, was effective upon publication. QUESTION 1: Under the Equal Credit Opportunity Act (ECOA) and its implementing Regulation B, creditors are required to provide applicants for first-lien loans on a dwelling with copies of appraisals, as well as other written valuations (collectively, “valuations”), developed in connection with the application […]
Month: April 2020
CORONA RELIEF – TRID AND RESCISSION WAITING PERIODS
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 […]
FRB Eliminates Six-Per-Month Regulation D Limit
On Friday, April 24, 2020, the Federal Reserve Board announced an interim final rule amending Regulation D to immediately delete the six-per-month limit on convenient transfers from the definition of savings deposit and allow financial institutions to immediately to suspend enforcement of the six-transfer limit. Compliance Resource has been anticipating this amendment and is pleased to see this announcement, as this action brings relief to customers needing to easily access savings deposit funds during the […]
AGENCIES DEFER APPRAISALS
On April 14, 2020 the Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Office of the Comptroller of the Currency, National Credit Union Administration, and the Consumer Financial Protection Bureau (jointly, the agencies) issued an interim final rule to temporarily defer real estate-related appraisals and evaluations under the interagency appraisal regulations. The agencies are providing this temporary relief to allow regulated institutions to extend financing to creditworthy households and businesses quickly […]
CLARIFICATION OF REVISED HMDA CLOSED-END THRESHOLD
As of January 1, 2020 the threshold for reporting closed-end loans for purposes of HMDA was 25 loans. As announced last Friday, on July 1, 2020 the threshold increases to 100 closed-end loans. As a result, institutions that originate: Fewer than 25 closed-end loans continue to be exempt from reporting closed-end loans for HMDA; 25 or more, but fewer than 100, closed-end loans become exempt from reporting closed-end loans for HMDA effective July 1, 2020 […]