Last month we published an article entitled Are You Libor Ready? On February 13 the Federal Reserve Bank of New York issued an Operating Policy Statement regarding publication of Secured Overnight Financing Rate (SOFR) averages and a SOFR Index to assist the transition to the new index. Publication of 30-, 90-, and 180-day SOFR Averages as well as a SOFR Index will begin March 2, 2020, in order to support a successful transition away from U.S. dollar
On February 10, 2020, the Financial Crimes Enforcement Network (FinCEN) issued ruling (FIN-2020-R001) on currency transaction reporting (CTR) requirements, FinCEN Form 112, involving sole proprietorships and legal entities operating under Doing Business As (DBA) names. The changes will be effective April 6, 2020, September 1 for E-Filing batch filers. This ruling replaces FIN-2006-R003 and FIN-2008-R001. For sole proprietorships the ruling states: Complete a single Part I “Person Involved in Transaction” section with the individual owner’s
2020 HMDA GUIDE
Category: CFPB, FFIEC, HMDA, Regulation C
On February 12, 2020 the Federal Financial Institutions Examination Council (FFIEC) published its 2020 version of A Guide to HMDA Reporting – Getting It Right. The Guide, which has been published since 1998, provides a summary of responsibilities and requirements, directions for assembling the necessary tools, and instructions for reporting HMDA data. The 2020 version is updated to include information from the final rule published by the CFPB in October 2019. Primarily, the 2020 Guide
On February 6, 2020 Kathleen Kraninger presented the Consumer Financial Protection Bureau’s (CFPB’s) Fall 2019 Semi-Annual Report to Congress, covering the period from .April 1, 2019, to September 30, 2019. The Report provides updates on a number of current regulatory efforts including, but not limited to: Payday, Vehicle Title, and Certain High-Cost Installment loans In February 2019, the CFPB released Notices of Proposed Rulemaking (NPRM) on the 2017 Payday, Vehicle Title, and Certain High-Cost Installment
DISCLOSURE OF GIFT EQUITY
Category: CFPB, Regulation Z, TRID, Truth in Lending
Recently we received the following question in our Community Forum: Question: When the amount of gift equity is known at the time of initial disclosure, should the gift equity amount be disclosed on the Loan Estimate in the calculating cash to close section as a seller credit or adjustments and other credits? There does not appear to be any clear cut guidance in 1026.37(H)(1)(vi) or (vii). Thank you Answer: A gift of equity can take
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