Archive

TRUMP STOPS NEW REGULATIONS, OR NOT

On January 20, 2017, White House Chief of Staff Reince Priebus issued a memorandum (the “Priebus Memo”) to the heads of executive departments and agencies instructing them to stop the regulation issuing process for a period of time. OK. So what does the Priebus memo mean to Compliance Geeks? It is not completely clear at the moment, but time will tell. Does the Priebus Memo apply to bank regulations? The memo is directed to executive […]

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TRID DELAY – NOT LIKELY

It is that season again. Every time we approach the effective date of a major regulatory change various financial institution associations make last-ditch efforts to delay the changes or the impact of the changes. The outcome is always the same – nothing changes. The Truth-in-Lending/RESPA Integrated Disclosures (TRID) changes are no exception. Recently the American Bankers Association (ABA) petitioned the Consumer Financial Protection Bureau (CFPB) to provide a grace period that would allow more time […]

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CFPB REGULATORY PRIORITIES FROM THE SEMIANNUAL REGULATORY AGENDA

The CFPB’s regulatory priorities for the semiannual period ending October 31, 2014, include continuing work to implement Dodd-Frank Act mortgage protections, a series of rulemakings to address critical issues in other markets for consumer financial products and services, and following up on earlier efforts to streamline and modernize regulations that the CFPB has inherited from other Federal agencies.   Implementing Dodd-Frank Act Mortgage Protections A major effort of the CFPB is the implementation of its […]

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WHAT IS AN EFFECTIVE DATE?

Whenever federal financial institution regulatory agencies issue new final regulations they include an effective date. We have all seen, “The rule is effective January 10, 2014” or “The rule is effective for applications received on or after January 10, 2014,” but what does that mean. Apparently the term “effective date” means different things to different people. For financial institution regulatory agencies the term “effective date” apparently refers to the date by which a financial institution […]

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PERMISSIBLE PAYMENTS TO LOAN ORIGINATORS

Recently I received a question about appropriate methods of compensating loan originators. Section 1026.36(d) of Regulation Z prohibits payments to loan originators based on the terms of the transaction. Restrictions on compensation to loan originators have been in place for several years. The latest revisions to the rules are effective January 10, 2014. While there are several significant issues resolved by the January 10th revisions, the question involved a less significant part of the rules. […]

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