Archive

REGULATION Z THRESHOLD ADJUSTMENTS FOR 2020

On August 1, 2019, the Consumer Financial Protection Bureau (CFPB) released a final rule updating certain Regulation Z threshold amounts for 2020.  The adjusted thresholds affect amounts under the Credit Card Accountability Responsibility and Disclosure Act of 2009 (CARD Act), the Home Ownership and Equity Protection Act of 1994 (HOEPA), and the Dodd-Frank Wall Street Reform and Consumer Protection Act (Qualified Mortgages). The adjusted amounts, effective January 1, 2020, include: The open-end consumer credit minimum […]

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QM Changes Considered

On July 25 the Consumer Financial Protection Bureau (CFPB) published a 30-page Advance Notice of Proposed Rulemaking (ANPR) seeking comments relating to the scheduled January 10, 2021, expiration of the temporary qualified mortgage provision applicable to loans eligible for purchase or guarantee by the Government Sponsored Enterprises, Fannie Mae and Freddie Mac. That provision is in the CFPB’s Ability to Repay/Qualified Mortgage (ATR/QM) Rule (section 1026.43 of Regulation Z).   The Bureau is considering whether […]

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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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ATR/QM ASSESSMENT

The Dodd-Frank Act (DFA) requires the CFPB to review certain rules within five years after they take effect. The required reviews are called assessments. The CFPB is conducting an assessment of the ATR/QM rule, and will issue a report of the assessment by January 2019. As required by law, the assessment will address the rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act and the specific goals of the […]

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CFPB RELEASES RURAL AND UNDERSERVED AREAS TOOL

This week the Consumer Financial Protection Bureau (CFPB) issued its Rural and Underserved Areas Tool linked here https://www.consumerfinance.gov/rural-or-underserved-tool/. The tool is designed to assist creditors in determining if properties are located in a rural or underserved area and eligible for certain exemptions from various requirements provided to certain small creditors under the CFPB’s mortgage rules. The Rural and Underserved Areas Tool is a the result of a final rule approved by the CFPB on September […]

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