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FINANCIAL CHOICE ACT

On April 26, 2017 Representative Hensarling’s Financial Services Committee published the Financial CHOICE Act, HR 10. According to the Executive summary the bill will: End “Too Big to Fail” and Bank Bailouts Demand Wall Street Accountability through enhanced penalties for fraud and deception Demand accountability from financial regulators and devolve power away from Washington Provide for election to be a strongly capitalized, well managed financial institution Unleash opportunities for small businesses, innovators, and job creators […]

TRUMP STOPS NEW REGULATIONS, OR NOT

On January 20, 2017, White House Chief of Staff Reince Priebus issued a memorandum (the “Priebus Memo”) to the heads of executive departments and agencies instructing them to stop the regulation issuing process for a period of time. OK. So what does the Priebus memo mean to Compliance Geeks? It is not completely clear at the moment, but time will tell. Does the Priebus Memo apply to bank regulations? The memo is directed to executive […]

CFPB REGULATORY PRIORITIES FROM THE SEMIANNUAL REGULATORY AGENDA

The CFPB’s regulatory priorities for the semiannual period ending October 31, 2014, include continuing work to implement Dodd-Frank Act mortgage protections, a series of rulemakings to address critical issues in other markets for consumer financial products and services, and following up on earlier efforts to streamline and modernize regulations that the CFPB has inherited from other Federal agencies.   Implementing Dodd-Frank Act Mortgage Protections A major effort of the CFPB is the implementation of its […]

WHAT IS AN EFFECTIVE DATE?

Whenever federal financial institution regulatory agencies issue new final regulations they include an effective date. We have all seen, “The rule is effective January 10, 2014” or “The rule is effective for applications received on or after January 10, 2014,” but what does that mean. Apparently the term “effective date” means different things to different people. For financial institution regulatory agencies the term “effective date” apparently refers to the date by which a financial institution […]

POINTS AND FEES – INDEX RATE FOR PERSONAL PROPERTY

When calculating points and fees §1026.32(b)(1)(i)(E and F) allow the creditor to exclude from the calculation up to two bona fide discount points under §1026.32(b)(1)(i)(E), or up to one bona fide discount point under §1026.32(b)(1)(i)(F),  paid by the consumer in connection with the transaction, if certain conditions are met. When a loan is secured by personal property, such as a mobile home, the condition is that the interest rate without any discount does not exceed […]