Archive

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, […]

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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 […]

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CFPB PUBLISHES ADDITIONAL THRESHOLDS FOR REGULATIONS M AND Z

On October 30, 2019 the CFPB published final rules in the Federal Register adjusting exemptions thresholds in Regulations Z and M for the year 2020. Comment 35(c)(2)(ii)-3.vii will be added to the Official Interpretations of § 1026.35 of Regulation Z to increase the threshold amount to $27,200 for the exemption from the special appraisal requirements for higher-priced mortgage loans. Comment 3(b)-3.xi will be added to the Official Interpretations of § 1026.3 of Regulation Z to increase the threshold amount […]

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TRID AND THE END OF DAYLIGHT SAVING TIME

Daylight Saving Time (DT) 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 that observe DT need to remember to change the […]

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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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