Archive

AGENCIES INCREASE REGULATION M AND Z THRESHOLDS

On November 29, 2021 the Office of the Comptroller of the Currency, Treasury (OCC); Board of Governors of the Federal Reserve System (Board); and Bureau of Consumer Financial Protection (Bureau) announced new coverage thresholds for: Consumer Leasing (Regulation M) – Based on the annual percentage increase in the CPI-W as of June 1, 2021, the exemption threshold will increase from $58,300 to $61,000 effective January 1, 2022. Appraisal for Higher-Priced Mortgage Loans Exemption Threshold – […]

REGULATION Z THRESHOLDS PUBLISHED

On October 25, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z and its Official Interpretations. The final rule revises the dollar amounts for provisions implementing TILA and amendments to TILA, including 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 (Dodd-Frank Act). The CFPB is […]

REVISED REGULATION Z EXAMINATION PROCEDURES

On October 25, 2021, the Board of Governors of the Federal Reserve System issued Consumer Affairs Letter (CA 21-14) announcing revised Interagency Examination Procedures for Regulation Z. The comprehensive procedures are 384 pages in length. The revised procedures reflect amendments to Regulation Z published by the Consumer Financial Protection Bureau in 2020 and 2021: Implementing permanent changes to Regulation Z’s qualified mortgage provisions, and Implementing an extension and phase-out for the GSE Patch, which had […]

TRID AND THE END OF DAYLIGHT SAVING TIME

Daylight Saving Time (DT) ends on November 7, 2021 at 2:00 a.m. What does DST 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 […]

ADDITIONAL CFPB GUIDANCE ON JUNETEENTH

On August 5, 2021, the CFPB released an interpretive rule to assist the mortgage industry in determining whether to treat JuneĀ 19, 2021, as a federal holiday or a business day for purposes of compliance with certain time-sensitive borrower protections. Regulation Z establishes timing requirements, calculated in business days, for when borrowers must receive certain disclosures and when borrowers have the right to cancel some mortgages. Because the Juneteenth National Independence Day Act was signed into […]