Archive

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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PACE FINANCING – ADVANCED NOTICE OF PROPOSED RULEMAKING

On May 24, 2018 the Economic Growth, Regulatory Relief, and Consumer Protection Act was signed into law. Among its many provisions Section 307 amends the Truth in Lending Act (TILA) to mandate that the Consumer Financial Protection Bureau (CFPB) prescribe certain regulations relating to residential Property Assessed Clean Energy (PACE) financing. Specifically, the regulations must carry out the purposes of TILA’s ability-to-repay (ATR) requirements, currently in place for residential mortgage loans, with respect to PACE […]

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PREPAID ACCOUNTS – EXAMINATION PROCEDURES

The Federal Deposit Insurance Corporation has released examination procedures for Prepaid Accounts to incorporate the Consumer Financial Protection Bureau’s (CFPB) amendments to Regulation E and Regulation Z. The examination procedures may be helpful to financial institutions seeking to better understand how examiners will evaluate an institution’s compliance with the prepaid account rule.. On October 3, 2016, the CFPB published its Final Rule for Prepaid Accounts to create comprehensive consumer protections for prepaid accounts. Specifically, the […]

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CFPB ISSUES TRID GUIDANCE

On January 25, 2019 the Consumer Financial Protection Bureau released four Frequently Asked Questions (FAQs) Related to TRID. The first three questions deal with corrected disclosures and the three-day waiting period before closing. The final questions involves a form issue. The questions and answers are available below and by clicking here. If there is a change to the disclosed terms after the creditor provides the initial Closing Disclosure, is the creditor required to ensure the […]

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Final 2019 Lending Thresholds Released

On December 31, 2018, with the last few hours of 2018 quickly approaching, the Consumer Financial Protection Bureau has published the final lending threshold updates just in time for 2019. The updates include: The HMDA asset-size exemption threshold, increased from $45 million to $46 million. The final rule is available here. The Truth in Lending asset-size exemption for certain creditors to qualify for an exemption to the requirement to establish an escrow account for a […]

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