David Mulkerin

On August 21, 2020, the CFPB released the 2021 HMDA Filing Instructions Guide (FIG) for data collected in 2020 and reported in 2021. Besides changing the references of “2020” to “2021,” the other changes are less cosmetic, such as updated descriptions and instructions for certain fields and revisions to certain edits. Also, we note they […]

Based on the 0.1% increase in the Consumer Price Index (CPI-W) in effect on June 1, 2020, the Consumer Financial Protection Bureau (CFPB) released a number of new triggering thresholds which go into effect on January 1, 2021. They include: The minimum interest charge disclosure threshold of $1.00 under the CARD Act will remain unchanged.

The Consumer Financial Protection bureau released a Statement on Supervisory and Enforcement Practices Regarding Electronic Credit Card Disclosures in Light of the COVID-19 Pandemic. This is described as a temporary and targeted flexibility for credit card issuers during this pandemic regarding the electronic provision of certain disclosures required to be in writing. Regulation Z generally

The CFPB released a Regulation E Update regarding remittance transfers and increasing the safe harbor threshold from 100 to 500 transactions per calendar year, effective July 21, 2020. Regulation E requires remittance transfer providers to provide customers with certain disclosures and establishes cancellation and error resolution procedures for these foreign transactions. Also, the update memorialized

On April 29, 2020, the Consumer Financial Protection Bureau released an interpretive ruling effective on May 4, 2020 providing rescission relief. If a consumer refinances or applies for a mortgage loan and needs funds due to the COVID-19 pandemic before the end of the waiting periods, lenders can waive and modify the waiting period for

It’s the end of an era. I have been in audit or compliance for {shudder} over 30 years now, and in all that time have had APRWin as a constant companion to test the validity of those APRs. It’s like an old friend. The current version has been around since May 2008. APYWin isn’t quite

On April 16, 2020, the CFPB released a final rule affecting the thresholds for HMDA reporting. To assist with understanding the transition, the Bureau has published new resources and updated some existing ones: Unofficial, informal redline to reflect changes to Regulation C Executive Summary HMDA Rule Key Dates Timeline 2020-2022 HMDA institutional coverage chart, effective

On April 14, 2020 the OCC, FRB and FDIC issued an interim final rule effective April 17, 2020 until December 31, 2020 (comments due June 1, 2020) which will amend the agencies’ regulations requiring appraisals of real estate for certain transactions. (NOTE: This rule was finalized on October 16, 2020.) Under the interim final rule,

In case you missed the CFPB announcements, the Bureau released two Policy Statements earlier this year. One statement addressed the prohibition on Abusive acts or practices and another notice described a new designation for some Bureau guidance, known as “Compliance Aids,” used to explain the legal status and role of guidance with that designation. Compliance