Archive

SET YOUR CLOCKS BACK AND CHECK YOUR TRID DISCLOSURES

Correction 10/27/2016: This article, initially posted on Wednesday, October 26th, 2016, included the designation “Eastern” in the first two paragraphs. All references to the designation “Eastern” have been removed from these paragraphs. It’s that time of year again. Daylight Saving Time, or Daylight Time (DT), ends on November 6, 2016 at 2:00 a.m. If your financial institution is in an area that observes Daylight Savings Time, ensure the time zone designation is updated to reflect […]

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EFFECTIVE DATE FOR FINAL SERVICING RULES ESTABLISHED

On October 19, 2016 the final Servicing Rules published by the Consumer Financial Protection Bureau on August 6, 2016 were finally published in the Federal Register. The final rule clarifies, revises, or amends provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions. The final rule also addresses proper compliance regarding certain servicing requirements […]

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MILITARY LENDING ACT EXAMINATION PROCEDURES

On October 17. 2016 the FDIC released revised interagency examination procedures that reflect the Department of Defense’s (DOD) 2015 amendments to the implementing regulations of the Military Lending Act of 2006 (MLA) and its August 2016 interpretive rule that provides guidance on certain questions received regarding compliance with the MLA rule. During early examinations, examiners will evaluate financial institutions’ compliance management systems and overall efforts to come into compliance. Specifically, examiners will consider an institution’s […]

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PREPAID ACCOUNTS JUST GOT KICKED UP TO THE CONSUMER PROTECTION SUITE

On October 3, 2016 the CFPB issued its final rule for general purpose prepaid accounts which will generally go into effect on October 1, 2017.   This culminated a 4+ year wait since the CFPB announced its initial intention to regulate prepaid accounts and 2 years from its proposal.  The CFPB’s initial 870 page ANPR has morphed into a 1,689-page final rule so it’s easy to determine that numerous products and requirements were added on that […]

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