Archive

GUIDANCE ON VOLUNTARY PRIVATE EDUCATION LOAN REHABILITATION PROGRAMS

On February 4, 2019 the Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution letter (FIL-5-2019) dealing with voluntary private education loon rehabilitation programs. The notice was issued jointly with the Board of Governors of the Federal Reserve System (Fed). The FIL is designed to make financial institutions aware of an amendment to section 623 of the Fair Credit Reporting Act (FCRA). This amendment is contained in section 602 of the Economic, Growth, Regulatory Relief […]

Read More…

HAPPY NEW YEAR!

2018 was an interesting year for those of us in the compliance field. We completed implementation of HMDA and TRID revisions, and got a jump start on implementing the provisions of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA). In last year’s New Years greeting I stated, “In my 42-year career I have seen the pendulum swing from one extreme to another several times. Since the mortgage crisis 10 years ago we have […]

Read More…

AGENCIES PROPOSE AMENDMENTS TO REGULATIONS CC AND DD

On November 21, 2018 the Bureau of Consumer Financial Protection (the Bureau) and the Federal Reserve Board (FRB), collectively the Agencies, proposed amendments to Regulation CC, the implementing regulation for the Expedited Funds Availability (EFA) Act, that would allow for adjustments in amount of funds depository institutions must make available to customers. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) amended the EFA Act giving joint rulemaking authority to the Bureau and […]

Read More…

CREDIT FREEZES AND OTHER CREDIT REPORT ISSUES

Section 301 of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA): Requires free placement and removal of security freezes by establishing a public webpage with links to credit reporting agency security freeze web pages. Requires Equifax, Experian and TransUnion to each set up a webpage for requesting fraud alerts and credit freezes. Provides additional ID theft protections to minors. Requires the big three credit bureaus to offer free electronic credit monitoring services to […]

Read More…

HMDA FINAL RULE FOR EGRRCPA EXEMPTION

On August 31 the Bureau of Consumer Financial Protection issued a final rule to implement and clarify the requirements of section 104(a) of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA), which amended certain provisions of the Home Mortgage Disclosure Act (HMDA).┬áThe rule clarifies: That insured depository institutions and insured credit unions covered by a partial exemption under the EGRRCPA have the option of reporting exempt data fields as long as they report […]

Read More…