The CFPB recently issued a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA) requirement to maintain an escrow account for a higher-priced mortgage loan (HPML)....more
12/24/2024
/ Asset Management ,
Consumer Financial Protection Bureau (CFPB) ,
Economic Growth Regulatory Relief and Consumer Protection Act ,
Escrow Accounts ,
Exemptions ,
Final Rules ,
High-Priced Mortgage Loans (HPML) ,
Loans ,
Mortgages ,
Regulation Z ,
Threshold Requirements ,
Truth in Lending Act (TILA)
The CFPB has issued a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z under the Truth in Lending Act (TILA) that implement the CARD Act, Home Ownership and Equity...more
The CFPB, Fed, and OCC have announced that they are increasing exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2025 through December 31, 2025, these exemption thresholds are...more
10/18/2024
/ Appraisal ,
Consumer Financial Protection Bureau (CFPB) ,
Exemptions ,
Federal Reserve ,
Financial Institutions ,
Inflation Adjustments ,
Loans ,
Mortgages ,
OCC ,
Regulation M ,
Regulation Z ,
Threshold Requirements
The National Consumer Law Center is asking the CFPB, by way of a petition, for rulemaking that is long on policy arguments but woefully short on legal support, as we note below, to define residential leases as “credit” under...more
8/28/2024
/ Administrative Procedure Act ,
Anti-Discrimination Policies ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Credit Reports ,
Creditors ,
Data Collection ,
ECOA ,
Fair Credit Reporting Act (FCRA) ,
Final Rules ,
Financial Services Industry ,
NCLC ,
Proposed Rules ,
Regulation B ,
Regulation Z ,
Residential Leases ,
Small Business ,
Truth in Lending Act (TILA)
The U.S. Department of Veterans Affairs (VA) recently proposed rules under its home loan guaranty program regarding adjustable rate mortgage (ARM) loans, hybrid ARM (h-ARM) loans and temporary buydown agreements. Comments are...more
6/25/2024
/ Adjustable-Rate Mortgage ,
Consumer Financial Products ,
Department of Veterans Affairs ,
Financial Regulatory Reform ,
Financial Services Industry ,
Interest Rates ,
Loans ,
Mortgage Lenders ,
Proposed Rules ,
Regulation Z ,
Regulatory Agenda ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Veterans
The U.S. Department of Housing and Urban Development (HUD), through the Federal Housing Administration (FHA), recently issued Mortgagee Letter 2024-07 addressing reconsideration of value (ROV) policies in connection with...more
5/10/2024
/ Appraisal ,
Bias ,
Borrowers ,
Fannie Mae ,
Federal Housing Administration (FHA) ,
Financial Services Industry ,
Freddie Mac ,
HUD ,
Mortgagee Letters ,
Mortgages ,
Regulation Z ,
Truth in Lending Act (TILA)
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more
The CFPB has released its Fall 2023 rulemaking agenda as part of the Fall 2023 Unified Agenda of Federal Regulatory and Deregulatory Actions. The agenda’s preamble indicates that “[t]he Bureau reasonably anticipates having...more
12/8/2023
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Cards ,
Dodd-Frank ,
Fair Credit Reporting Act (FCRA) ,
Financial Regulatory Reform ,
Financial Services Committee ,
Financial Services Industry ,
Late Fees ,
Mortgage Servicing Rules ,
Overdraft Fees ,
Popular ,
Regulation DD ,
Regulation Z ,
Regulatory Agenda ,
Truth in Lending Act (TILA)
The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments. Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more
11/15/2023
/ Consumer Financial Protection Bureau (CFPB) ,
Credit ,
Exemptions ,
Federal Reserve ,
Financial Institutions ,
Financial Regulatory Reform ,
Financial Services Industry ,
Financial Transactions ,
Inflation Adjustments ,
Loans ,
Mortgages ,
OCC ,
Proposed Rules ,
Regulation M ,
Regulation Z ,
Threshold Requirements ,
Truth in Lending Act (TILA)
The Consumer Financial Protection Bureau and Department of Justice have issued a joint statement regarding “the potential civil rights implications of a creditor’s consideration of an individual’s immigration status under the...more
10/17/2023
/ Ability-to-Repay ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Department of Justice (DOJ) ,
Discriminatory Lending Practices ,
ECOA ,
Financial Services Industry ,
Immigration ,
Immigration Status Discrimination ,
Joint Statements ,
Regulation B ,
Regulation Z
The CFPB recently posted on its website a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified...more
9/19/2023
/ CARD Act ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Price Index ,
Credit Cards ,
Dodd-Frank ,
Final Rules ,
Financial Services Industry ,
HOEPA ,
Late Fees ,
Mortgages ,
Proposed Rules ,
Regulation Z
The CFPB has released the Summer 2023 edition of Supervisory Highlights. The report discusses the Bureau’s examinations in the areas of auto origination and servicing, consumer reporting, debt collection, deposits, mortgage...more
7/31/2023
/ Bank Deposits ,
Borrowers ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Reporting Agencies ,
Consumer Reports ,
Debt Collection ,
ECOA ,
Fair Lending ,
Financial Services Industry ,
Lenders ,
Military Lending Act ,
Mortgages ,
Regulation B ,
Regulation X ,
Regulation Z ,
Supervisory Highlights ,
UDAAP
The Economic Growth, Regulatory Relief, and Consumer Protection Act (Act) directs the CFPB to prescribe Truth in Lending Act (TILA) ability-to-repay (ATR) rules for Property Assessed Clean Energy (PACE) financing. The CFPB...more
The CFPB recently announced that it is conducting a review of the Regulation Z mortgage loan originator rules under the Regulatory Flexibility Act (RFA) and is seeking comments on the economic impact of the rules on small...more
The CFPB recently issued a final rule increasing the asset exemption threshold under the Home Mortgage Disclosure Act (HMDA) and a final rule increasing the asset exemption threshold for the Truth in Lending Act (TILA)...more
On December 23, the CFPB published a final rule in the Federal Register regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability...more
The Federal Reserve Board issued a proposal last week that would establish default rules for benchmark replacements in certain contracts that use as a reference rate the London Interbank Offered Rate (LIBOR), which will be...more
The CFPB has released the Spring 2022 edition of its Supervisory Highlights. The report discusses the Bureau’s examinations in the areas of auto servicing, consumer reporting, credit card account management, debt collection,...more
As previously reported, the creation on June 17, 2021 of the Juneteenth National Independence Day resulted in an important change under the Truth in Lending Act (TILA) and Regulation Z. The CFPB recently issued an...more
On June 23, 2021, President Biden replaced the Federal Housing Finance Agency (FHFA) Director Mark Calabria with Acting Director Sandra L. Thompson....more
As previously reported, the bill signed into law by President Biden on June 17, 2021 to create the Juneteenth National Independence Day actually results in an important change under the Truth in Lending Act (TILA) and...more
The bill signed into law by President Biden on June 17, 2021 to create the Juneteenth National Independence Day results in an important change under the Truth in Lending Act (TILA) and Regulation Z....more
The CFPB recently entered into a consent order with Nationwide Equities Corporation (Nationwide), which the CFPB refers to as a mortgage broker and mortgage lender that primarily provides jumbo reverse mortgage loans and Home...more
As previously reported, the CFPB proposed to delay the mandatory compliance date for the new general qualified mortgage (QM) rule that amends the Regulation Z ability to repay/QM rule from July 1, 2021 to October 1, 2022....more
As previously reported, the Economic Growth, Regulatory Relief, and Consumer Protection Act (Growth Act), passed in June 2018, created an exemption from the requirement to maintain an escrow account in connection with a...more