Military Lending Act – Are You Ready?

Compliance with the Military Lending Act changes will go into effect on October 3 (credit card compliance is not until October 3, 2017), and many credit unions are still trying to work out the details.  The Department of Defense has repeatedly promised guidance, but has not yet delivered.  Needless, the credit union must comply with the requirements beginning next month.  … Read More

Browser requirements for NMLS access

The NMLS announced, that starting August 22, NMLS users who are not using internet browsers that support TLS 1.2 will need to upgrade by October 8. After October 8, users who have not upgraded their browsers will be restricted from accessing NMLS until they have downloaded a version that supports TLS 1.2.  Should you have any questions, please visit the … Read More

Legal Opinion Letter 16-0604 – MBL Reporting

On August 9, the NCUA issued a legal opinion letter regarding the classification of business loans.  Essentially, when a single closed-end member business loan is paid down below the $50,000 threshold, the credit union no longer needs to classify the loan as a MBL.  Nor does the credit union include the loan when calculating the credit union’s statutory MBL limit. … Read More

Loss Mitigation Principles

The CFPB and the U.S. Department of Housing both recently released principles for loss mitigations (CFPB, HUD).  The papers result from the mortgage crisis and phasing out of the Home Affordable Modification Program (HAMP).  The documents do not establish any new requirements, but outline principles that should be incorporated into loss mitigation strategies.  The CFPB outlines four principles:  accessibility, affordability, … Read More

Proposed Amendments to Regulation Z Mortgage Disclosure Requirements

The CFPB issued proposed changes to amend the KBYO/TRID rules of Regulation Z.  The CFPB states that the proposed amendments memorialize its informal guidance on various issues and includes clarifications and technical amendments.  There are a number of proposed changes in proposal, but are not intended to revisit major policy decisions so soon after the October 2015 effective date. Comments … Read More

Final Rules on Foreclosure Protections – Delinquency and Multiple Loss Mitigation Procedures

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protection – Borrower’s In Bankruptcy

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protections – Successors in Interest

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protections – Loss Mitigation Procedures

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More

Final Rules on Foreclosure Protection – Servicing Transfers

On August 4, the CFPB issued Final Rules providing foreclosure protections.  The Rules, consisting of 901 pages, address foreclosure protections, successors in interest, borrowers in bankruptcy, loss mitigation, servicing transfers, and loss mitigation applications.  The Rules consist of a number of amendments to Regulation X and Regulation Z, their respective Official Interpretations, and model forms and clauses.  Along with the … Read More