Archive

PROPOSED INCREASE OF APPRAISAL THRESHOLD FOR COMMERCIAL REAL ESTATE

On July 19, 2017, the Federal Reserve Board (FRB), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking to raise the threshold for commercial real estate transactions requiring an appraisal to $400,000. This proposed rule is an effort by the agencies to address concerns about time and cost burdens related to real estate transactions without compromising the safety and soundness of financial […]

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CFPB LOSSES FIGHT WITH SMALL FAMILY-OWNED LAW FIRM

No question about it – the CFPB will bully you when they can. This time David fought back and defeated Goliath. In 2013 the Consumer Financial Protection Bureau (CFPB) sued Borders and Borders PLC, a small family-owned law firm located in Louisville, KY. The CFPB alleged that the firm and principals Harry Borders,  John Borders, Jr. and J. David Borders accepted kickbacks in exchange for referrals of real-estate closing services. Most companies cannot afford to […]

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HMDA – PROPOSED HELOC CHANGE

On July 14, 2017 the Consumer Financial Protection Bureau (CFPB) proposed amendments to Regulation C that would, for a period of two years, increase the threshold for collecting and reporting data with respect to open-end lines of credit so that financial institutions originating fewer than 500 open-end lines of credit in either of the preceding two years would not be required to begin collecting such data until January 1, 2020. Through outreach, the CFPB has […]

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ANOTHER TRID PROPOSAL

Right on the heels of the release of the 2017 TRID-RESPA Amendments final rule, the CFPB released a proposal today that also impacts TRID.  The proposed amendment released in July 2016 contained comments related to utilizing a Closing Disclosure to determine if a closing cost was disclosed in good faith.  The CFPB determined, based on comments received from the proposal, that many thought the amendment “would broaden creditors’ ability to compare charges paid by or […]

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