We are not sure when it occurred, but HUD slipped in two changes to the SCRA notice since it was last changed in March 2018. Both changes are in the final section within two bullet points. In the first bullet point, the website address for the Military Legal Assistance Office Locator was shortened, presumably to […]
SCRA Notice Changes Read More »
On August 21, 2020, the CFPB released the 2021 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides changing the references of “2020” to “2021,” the other changes are less cosmetic, such as updated descriptions and instructions for certain fields and revisions to certain edits. Also, we note they
Ready for HMDA 2021 Filing? Read More »
Based on the 0.1% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2020, the Consumer Financial Protection Bureau (CFPB) released a number of new triggering thresholds which go into effect on January 1, 2021. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged.
Lots of Regulation Z Updates Read More »
The Consumer Financial Protection bureau released a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. This is described as a temporary and targeted flexibility for credit card issuers during this pandemic regarding the electronic provision of certain disclosures required to be in writing. Regulation Z generally
Limited Open-End Credit eSign Exemption Due to COVID-19 Read More »
Ever since I’ve been in banking, Congress was going to relax the six-transaction limitation from savings and money market accounts. We won’t talk about how long that’s been, but it’s been a while. All it took was a global pandemic. Bankers and consumers have gotten their wish. (Actually, the FRB has been looking at this
UPDATE: Unlimited Savings Withdrawals Are a Reality Read More »
The CFPB released a Regulation E Update regarding remittance transfers and increasing the safe harbor threshold from 100 to 500 transactions per calendar year, effective July 21, 2020. Regulation E requires remittance transfer providers to provide customers with certain disclosures and establishes cancellation and error resolution procedures for these foreign transactions. Also, the update memorialized
Big Increase to Foreign Remittance Transfer Threshold Read More »
On April 29, 2020, the Consumer Financial Protection Bureau released an interpretive ruling effective on May 4, 2020 providing rescission relief. If a consumer refinances or applies for a mortgage loan and needs funds due to the COVID-19 pandemic before the end of the waiting periods, lenders can waive and modify the waiting period for
CFPB Waives TRID and Rescission Timeframes Read More »
It’s the end of an era. I have been in audit or compliance for {shudder} over 30 years now, and in all that time have had APRWin as a constant companion to test the validity of those APRs. It’s like an old friend. The current version has been around since May 2008. APYWin isn’t quite
APRWin and APYWin Replaced with Web Versions Read More »
On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. To assist with understanding the transition, the Bureau has published new resources and updated some existing ones: Unofficial, informal redline to reflect changes to Regulation C Executive Summary HMDA Rule Key Dates Timeline 2020-2022 HMDA institutional coverage chart, effective
HMDA Reporting Threshold Changes for 2020 and Beyond Read More »
On April 14, 2020 the OCC, FRB and FDIC issued an interim final rule effective April 17, 2020 until December 31, 2020 (comments due June 1, 2020) which will amend the agencies’ regulations requiring appraisals of real estate for certain transactions. (NOTE: This rule was finalized on October 16, 2020.) Under the interim final rule,
Agencies Release Interim Final Rule on Deferral of Appraisals/Evaluations Read More »
We’re here to review your current compliance strategy and help you find A Better Way to manage risk.
