Archive

SET YOUR CLOCKS BACK AND CHECK YOUR TRID DISCLOSURES

It’s that time of year again. Daylight Saving Time, or Daylight Time (DT), ends on November 5, 2017 at 2:00 a.m. If your financial institution is in an area that observes Daylight Savings Time, ensure the time zone designation has been updated to reflect Standard Time (ST) on your TRID disclosures. Under the TRID rules in Regulation Z creditors must disclose the date and time (including the applicable time zone): When the interest rate lock […]

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FHFA ADDS LANGUAGE PREFERENCE QUESTION TO URLA

Recently the Federal Housing Finance Agency (FHFA) announced its decision to add a preferred language question to the redesigned Uniform Residential Loan Application (URLA).  This question will enable borrowers who prefer to communicate in a language other than English to identify that language.  It also provides clear disclosures that the mortgage transaction is likely to be conducted in English and that language resources may not be available. The addition of this question is part of […]

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INTERAGENCY HMDA KEY FIELDS PUBLISHED

The FRB, the FDIC, and the OCC recently issued Designated Key HMDA Data Fields to support the efficient and effective evaluation of financial institutions’ compliance with the HMDA’s requirements. Of 110 data fields, 37 are identified as key fields. In certain circumstances, however, examiners may determine it necessary to review additional HMDA data fields, as appropriate. Background The HMDA, which is implemented by Regulation C (12 CFR 1003), requires certain financial institutions to collect, record, […]

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CFPB Releases Update on HMDA Tools

The CFPB released a statement October 18, 2017 to provide insight into when to expect the introduction of the HMDA Platform, the web interface required to submit 2017 HMDA data.  The HMDA Platform is one of the most anticipated tools for those financial institutions required to report for HMDA. The agency stated that it is “currently demonstrating to the industry the new HMDA Platform’s functionality and user experience through webinars, industry conferences, and in-person user […]

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FINAL PAYDAY RULES

On October 5, 2017 the Consumer Financial Protection Bureau (CFPB) made available a final new rule, 12 CFR Part 1041 (Regulation OO), for Payday, Vehicle Title and Certain High-Cost Installment Loans. The 1,690 page rule is, for the most part, effective 21months after publication in the Federal Register. The rule is complex and controversial. The development of the rule involved over five years of research, outreach, and a review of more than one million comments […]

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