Archive

PROPOSED DEBT COLLECTION RULE

On May 7, 2019 the Consumer Financial Protection Bureau (CFPB) issued a proposed rule, contained in Regulation F, to implement the Fair Debt Collection Practices Act (FDCPA). The proposal establishes clear limits on the number of calls debt collectors may place to reach consumers on a weekly basis; clarifies how collectors may communicate lawfully using newer technologies, such as voicemail, email and text messages, that have developed since the FDCPA’s passage in 1977; and requires […]

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PROPOSED HMDA CHANGES

On May 2, 2019 the Consumer Financial Protection Bureau (CFPB) published a Notice of Proposed Rulemaking (NPRM), an Advanced Notice of Proposed Rulemaking (ANPR) and other items related to changes to Regulation C, which is the implementing regulation for the Home Mortgage Disclosure Act.  Notice of Proposed Rulemaking For closed-end mortgage loans, the NPRM proposes two alternatives that would permanently increase the coverage threshold from 25 to either 50 or 100 closed-end mortgage loans. For […]

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TRID ASSUMPTIONS FACT SHEET

On May 1 the Consumer Financial Protection Bureau (CFPB) published a fact sheet entitled Are Loan Estimates and Closing Disclosures Required for Assumptions?   The factsheet consists of two parts: (1) a flowchart; and (2) a narrative discussion. The flowchart is a quick reference that highlights the major questions to be answered when determining if a Loan Estimate and Closing Disclosure are required for the assumption transactions described above. The narrative discussion provides general information that […]

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CFPB RELEASES MODIFIED LARS

On March 29, the CFPB announced that the HMDA Modified Loan Application Register (LAR) data have been published for approximately 5,400 financial institutions. This is the first year in which additional data reported by certain institutions under the 2015 HMDA rule are available. The Modified LARs contain loan level information for 2018 on individual HMDA filers, modified to protect privacy. A copy of the CFPB’s press release is available here. The 2018 HMDA Modified LARs are […]

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