David Mulkerin

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

The Consumer Financial Protection Bureau (CFPB) amended the Home Mortgage Disclosure Act (Regulation C) and the Truth in Lending Act (Regulation Z), adjusting the asset-size exemption thresholds for banks, savings associations and credit unions. Like the CRA thresholds, the adjustments are due to the annual percentage increase in the Consumer Price Index for Urban Wage

It’s that time again. The NMLS 2019 Annual Renewal Period will begin November 1 and end December 31. Companies and individuals can prepare by making sure the information on their NMLS record is up to date. During this time, companies can complete their annual attestation that their record is up to date, pay their NMLS

On October 10, 2019, the CFPB released a final rule (not yet published in the Federal Register) extending the current 500 open-end credit threshold until January 1, 2022. This new rule is effective on January 1, 2020. In addition to the rule above, the Bureau has issued an Executive Summary and an “unofficial, informal” redline

Get ready to update those policies and procedures! On September 27, 2019, the OCC, FDIC and FRB, in concurrence with the CFPB, published a revision to the appraisal rules at 12 CFR 34, 225 and 323 increasing the threshold amount where a residential real estate transaction requires a state-licensed, certified appraiser from $250,000 to $400,000.