Archive

Happy New Year

This has been a year to remember. Unprecedented regulatory change (over 6,000 pages) have ruled the day. It appears that 2014 will also be a busy year, but we hope the pace and volume of change is more reasonable. All of us at Jack’s ComplianceResource thank you for reading Jack’s Blog this year and we look forward to serving you in 2014. We also wish a year of good health and prosperity for you and […]

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FLURRY OF YEAR-END THRESHOLD ADJUSTMENTS

The Consumer Financial Protection Bureau (CFPB) just completed the usual year-end chore of updating various thresholds. The changes are based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W) for various periods in 2013. Escrow Exemption for HPMLs – On December 30, 2013 the CFPB amended the official commentary that interprets the requirements of Regulation Z (Truth in Lending) to reflect a change in […]

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HMDA – HOEPA STATUS

Section 1003.4(a)(13) of Regulation C requires that the Loan Application Register indicate, among other items, whether the loan is subject to the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 CFR 1026.32). Under current rules a loan secured by a consumer’s principal dwelling is subject to HOEPA if the loan has a high rate or high fees. Currently a loan has high fees if the total points and […]

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CFPB – A LOOK AHEAD AT 2014

It appears that the Consumer Financial Protection Bureau (CFPB) will be busy during 2014, but a lot less busy than 2013. On December 3, 2014 the CFPB published a semi-annual update to its rulemaking agenda. The fall 2013 agenda reflects both continuing work on rulemakings mandated by the Dodd-Frank Act and significant issues in other markets for consumer financial products and services. In the past year the CFPB issued rules to implement Dodd-Frank Act requirements […]

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REVISED HPML APPRAISAL RULES

On December 12, 2013 the Federal Reserve Board, The Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the National Credit Union Administration, and the Office of the Comptroller of the Currency jointly published a final rule that creates exemptions from certain appraisal requirements for a subset of higher-priced mortgage loans. The exemptions are intended to save borrowers time and money while still ensuring that the loans are financially sound. […]

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