Archive

2019 GUIDE TO HMDA REPORTING RELEASED

The Federal Financial Institutions Examination Council (FFIEC) has released the 2019 edition of the publication, A Guide to HMDA Reporting – Getting it Right (aka the HMDA bible). The 2019 version includes amendments made to HMDA by the Economic Growth, Regulatory Relief, and Consumer Protection Act and the 2018 HMDA interpretive and procedural rule issued by the Consumer Financial Protection Bureau. A copy of the Guide is available at:  https://www.ffiec.gov/hmda/pdf/2019guide.pdf.   […]

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OCC FINES CITIBANK FOR FAIR HOUSING ACT VIOLATION

On March 19th, The Office of the Comptroller of the Currency (OCC) levied a $25 million civil money penalty against Citibank for violating the Fair Housing Act.  The violation stems from inconsistent issuing of lender credits through their Relationship Loan Pricing (RLP) program.  The OCC found that there were control weaknesses related to the program that resulted in eligible mortgage loan customers not receiving an interest rate reduction or a credit to their closing costs.  […]

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FDIC ELIMINATES ANNUAL DISCLOSURE STATEMENT REQUIREMENT

On March 18, 2019 the Federal Deposit Insurance Corporation (FDIC) issued a final rule rescinding its regulations at 12 CFR 350, entitled Disclosure of Financial and Other Information By FDIC-Insured State Nonmember Banks. Upon the effective date, all insured state nonmember banks and insured state licensed branches of foreign banks will no longer be subject to the annual disclosure statement requirements set out in the existing regulations at 12 CFR 350. The annual disclosure under […]

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PACE FINANCING – ADVANCED NOTICE OF PROPOSED RULEMAKING

On May 24, 2018 the Economic Growth, Regulatory Relief, and Consumer Protection Act was signed into law. Among its many provisions Section 307 amends the Truth in Lending Act (TILA) to mandate that the Consumer Financial Protection Bureau (CFPB) prescribe certain regulations relating to residential Property Assessed Clean Energy (PACE) financing. Specifically, the regulations must carry out the purposes of TILA’s ability-to-repay (ATR) requirements, currently in place for residential mortgage loans, with respect to PACE […]

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TRID AND DAYLIGHT SAVING TIME

Daylight Saving Time (DT) begins on March 10, 2019 at 2:00 a.m. It ends on November 3, 2019 at 2:00 a.m. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in areas […]

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