Archive

CFPB SPRING 2020 AGENDA

On June 30, 2020, the Consumer Financial Protection Bureau (CFPB) published its Spring 2020 Agenda. The agenda lists the regulatory matters that the CFPB expects to focus on between May 1, 2020 and April 30, 2021. Those matters include: A final rule amending the CFPB’s Remittance Rule to provide tailored exceptions that permit certain insured institutions to disclose estimates instead of exact amounts to consumers in certain circumstances. The final rule also increases (from 100 remittance […]

Read More…

PROPOSED REGULATION Z CHANGES FOR LIBOR TRANSITION

On June 4, 2020 the Consumer Financial Protection Bureau (CFPB) published a 219 page proposal to amend Regulation Z to facilitate creditors’ transition away from using the London Interbank Offered Rate (LIBOR) as an index for variable-rate consumer credit products. The CFPB is proposing changes to: Certain open-end and closed-end provisions to provide examples of replacement indices for LIBOR indices that meet certain Regulation Z standards. Certain open-end provisions restricting index changes, requiring change-in-terms notices, […]

Read More…

RECENT TRID GUIDANCE – FACTSHEET AND FAQS

On June 9 the Consumer Financial Protection Bureau (CFPB) published a nine-page booklet entitled Factsheet:  TRID Title Insurance Disclosures. The factsheet clarifies the disclosures for both Lender and Owner’s Title Insurance, including the disclosure of a simultaneous issuance. Several helpful examples are included. On June 9 the CFPB also published three new Frequently Asked Questions (FAQs). The new FAQs explain: Seller-Paid Loan Costs and Other Costs on Separate Closing Disclosures to the Seller and the […]

Read More…

REVISED CHARM BOOKLET

On June 9,2020 the Consumer Financial Protection Bureau (CFPB) announced the availability of an updated consumer publication, the Consumer Handbook on Adjustable Rate Mortgages booklet, also known as the CHARM booklet, required under the Real Estate Settlement Procedures Act (RESPA) implemented by Regulation X and the Truth in Lending Act (TILA) implemented by Regulation Z. New features include: A comparison table that describes adjustable rate mortgages and their differences in relation to fixed-rate loan products; […]

Read More…

ELECTRONIC CREDIT CARD DISCLOSURES AND COVID-19

On June 3, 2020 the Consumer Financial Protection Bureau (CFPB) issued a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. The Issue Where underlying law, such as Regulation Z, requires a written disclosure to a consumer, the Electronic Signatures in Global and National Commerce Act (E-Sign Act) allows the disclosure to be provided electronically subject to certain conditions, including consumers’ consent–commonly known as “E-Sign consent.” Some […]

Read More…