Archive

PROPOSED CHANGES TO REGULATIONS B AND C

The CFPB has been busy with proposed changes in recent weeks.  Two proposed changes released by the CFPB will impact most financial institutions to some degree.  The CFPB released proposed changes to Regulation B on March 24, 2017.  The proposal is designed to permit creditors additional flexibility in complying with Regulation B – ECOA, in order to facilitate compliance with Regulation C – HMDA.  This proposal was not unexpected.  In addition, the CFPB released changes […]

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EFFECTIVE DATE OF PREPAID ACCOUNT RULE DELAYED

On April 20, 2017, the Consumer Financial Protection Bureau (CFPB) issued a final rule which delays the effective date of the Prepaid Accounts Rule under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z) for six months, until April 1, 2018. The CFPB issued the Prepaid Account Rule on October 6, 2016 with an effective date of October 1, 2017. On March 16, 2017, the CFPB proposed delaying the […]

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CFPB ISSUES ANNUAL FAIR LENDING REPORT AND IDENTIFIES PRIORITIES FOR 2017

On April 14, 2017, the CFPB released its fifth Fair Lending Report reflecting the Bureau’s rulemaking, supervision, enforcement, interagency collaboration, and outreach activities for 2016 as well as its fair lending priorities for 2017. Perhaps most importantly for financial institutions is the Report’s identification of fair lending priorities for 2017, which includes redlining, mortgage and student loan servicing, and small business lending, as well as the method for identifying fair lending priorities. The Report notes […]

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HMDA CLARIFICATION

On April 13, 2017 the Consumer Financial Protection Bureau published 150-page proposed update to Regulation C. The changes should help financial institutions comply with the 2015 HMDA Final Rule by clarifying the information they are required to collect and report about their mortgage lending. The proposal contains a number of clarifications, technical corrections, and minor changes to the HMDA regulation. These include clarifying certain key terms, such as “temporary financing” and “automated underwriting system.” The […]

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HMDA – HUGE ERRORS, HUGE PENALTIES

Recently the Consumer Financial Protection Bureau (CFPB) ordered Nationstar Mortgage LLC, of Coppell, Texas, to pay a $1.75 million civil penalty for violating the Home Mortgage Disclosure Act (HMDA) by consistently failing to report accurate data about mortgage transactions for 2012 through 2014, and to take the necessary steps to improve its compliance management and prevent future violations. This is the largest HMDA penalty ever imposed by the CFPB. According to 2014 data, Nationstar was […]

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