David Mulkerin

FDIC sign

Deposit Insurance Changes for Trusts and Mortgage Servicing Accounts

On January 21, 2022 the FDIC notified insured Institutions of simplification for the calculation of Deposit Insurance for Trust Accounts and Mortgage Servicing Accounts which will be effective April 1, 2024 (so, plenty of time to ease into the change). If you don’t want to read the 62-page regulation, you can always read on, or

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mortgage application

HMDA and HPML Thresholds Bumped Up for 2022

The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations, and credit unions. Like the CRA thresholds, the adjustments are pegged to the annual percentage increase in the Consumer Price Index for Urban Wage

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loan stamp

A financial institution (FI) is adding a closing fee to the Loan Estimate (LE) due to a valid changed circumstance. The loan is set to close early next week and the FI needs to issue the Closing Disclosure (CD) in order to close on the borrower’s timeframe. Can the FI send both the revised LE and the initial CD on the same day?

Answer: No. Under Regulation Z, there has to be one day between the LE and CD. A revised LE must be issued no later than four business days prior to consummation and a CD must be issued at least three business days prior to consummation. However, Regulation Z does also permit us to provide changes

A financial institution (FI) is adding a closing fee to the Loan Estimate (LE) due to a valid changed circumstance. The loan is set to close early next week and the FI needs to issue the Closing Disclosure (CD) in order to close on the borrower’s timeframe. Can the FI send both the revised LE and the initial CD on the same day? Read More »

compliance drawing

HPML Appraisal & Regulation Z and Regulation M Exemption Dollar Thresholds for 2022

On November 30, 2021 the Federal Reserve Board and the Consumer Financial Protection Bureau jointly issued an increase in the exemption thresholds for Regulation Z and Regulation M exemptions, which are tied to the Consumer Price Index. Loans or leases at or below the thresholds are subject to the protections of the regulations. The regulators

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regulations block as piece of a puzzle

New Threshold Amounts for 2022 under Regulation Z CARD Act, HOEPA and QM Sections

Based on the 4.7% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2021, the Consumer Financial Protection Bureau (CFPB) released a number of new thresholds which go into effect on January 1, 2022. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged. (1026.6(b)(2)(iii)

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data compliance

Safe Act MLO Registration Renewal Period Starts November 1 – Check Current Registrants’ Names

It’s that time again. The NMLS 2021 Annual Renewal Period began on November 1 and will end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies can complete their annual attestation that their record is up to date, pay their

Safe Act MLO Registration Renewal Period Starts November 1 – Check Current Registrants’ Names Read More »

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