Archive

2020 HOME MORTGAGE DISCLOSURE ACT THRESHOLD INCREASE

On December 20, 2019 the Consumer Financial Protection Bureau published a final rule amending the official commentary that interprets the requirements of Regulation C (Home Mortgage Disclosure Act) to reflect the asset-size exemption threshold for banks, savings associations, and credit unions based on the annual percentage change in the average of the Consumer Price Index for Urban Wage Earners and Clerical Workers (CPI-W). For 2020 the exemption is increased to $47 million from $46 million. […]

Read More…

TRID CONSTRUCTION LOAN GUIDES

On Wednesday, Dec. 18, 2019, the Consumer Financial Protection Bureau (CFPB) published two guides on disclosing construction-only and construction-permanent loans with examples based on common questions received by the Bureau. The Combined Guide  provides guidance for disclosing the phases together and the Separate Guide  provides guidance for disclosing the phases separately. Alternate Headline: CFPB Publishes Inadequate TRID Construction Loan Guidance More Than Four Years After the Effective Date Have you ever heard the old saying , “a day late […]

Read More…

CFPB PUBLISHES FALL 2019 UNIFIED AGENDA

Recently the Consumer Financial Protection Bureau (CFPB) published its Fall 2019 rulemaking agenda. The agenda identifies the regulatory matters that the CFPB reasonably anticipates having under consideration during the period from October 1, 2019 to September 30, 2020. The following summaries a few key topics: Proposed Fair Debt Collection Rule (Regulation F) – The CFPB proposed Regulation F in May 2019.  Now the CFPB is testing consumer disclosures related to time-barred debt and, after testing, […]

Read More…

CFPB COMMENCES TRID ASSESSMENT

On November 20 the Consumer Financial Protection Bureau (CFPB) announced that it commencing an assessment of its TRID (Truth in Lending Act and Real Estate Settlement Procedures Act Integrated Disclosure) rules. The CFPB intends to address the TRID Rule’s effectiveness in meeting the purposes and objectives of Title X of the Dodd-Frank Act, the specific goals of the rule, and other relevant factors.  The public is invited to comment on the feasibility and effectiveness of […]

Read More…

CFPB FEELING PRESSURE FROM NINE-YEAR DELAY IN ISSUING REGULATIONS

Section 1071  of the Dodd-Frank Act required the Consumer Financial Protection Bureau (CFPB) to issue rules, by July 21, 2011, to implement requirements for HMDA-like data collection and reporting for small businesses and for women-owned and minority-owned businesses. Recently the California Reinvestment Coalition, the National Association for Latino Community Asset Builders, and two individual small business owners filed suit seeking a declaration that the CFPB’s failure to issue regulations implementing Section 1071 violates the Administrative […]

Read More…