March’s legislative update is available here.
The CFPB has issued a proposal to provide flexibility for lenders around the collection of applicants’ demographic data under the Home Mortgage Disclosure Act (Regulation C) and the Equal Credit Opportunity Act (Regulation B). Currently, under Reg B, creditors are prohibited from requesting information about consumers’ race or ethnicity, except to the extent required to monitor compliance with ECOA or … Read More
The Division of Credit Union published Bulletin B-17-07 regarding the reporting of assets in the process of liquidation. The Bulletin is reprinted below. Please refer to the original link for footnotes. Assets in the Process of Liquidation The purpose of this bulletin is to set guidelines for how examiners will evaluate assets in the process of liquidation during examinations. Specifically, … Read More
The FDIC’s Winter 2016 Supervisory Insights includes an article titled Credit Risk Trends and Supervisory Expectation Highlights, that identifies credit risk trends in commercial real estate along with agriculture, and oil and gas-related lending. The article contains good information regarding the conditions and trends in each of these areas, and is a recommended read for the policy makers in your … Read More
On February 23, the DCU released Bulletin B-17-04, Exam Focus for Consumer Protection Compliance During 2017 through 2020. The Bulletin details the compliance exam focus for 2017 – 2020. Exam Focus for Consumer Protection Compliance During 2017 through 2020 In March 2017, the Division of Credit Unions (Division) will complete its first cycle of enhanced consumer protection compliance exams for … Read More
The CFPB released a Request for Information into ways to expand access to credit for consumers who are credit invisible or who lack enough credit history to obtain a credit score. Traditional credit history includes a borrower’s payment of debts such as mortgages, credit cards, and other loans. It is used by lenders to decide who can get credit and … Read More
According to an announcement posted on the Military Lending Act (“MLA”) Website: Between February 9, 2017 and February 15, 2017 there was a problem with MLA Multiple Record Requests that prevented 149 request files from processing. The Defense Manpower Data Center advises any creditor who, during the time period in question, submitted a Multiple Record Request file that failed to … Read More
The NCUA issued its first 2017 Regulatory Alert to credit unions regarding the recent amendments to the Mortgage Servicing Rule, the CFPB’s FDCPA interpretive rule regarding safe harbors from FDCPA liability. The recent amendments to the Mortgage Servicing Rule clarify (i) Regulation X (RESPA) provisions regarding force-placed insurance notices, mortgage servicing policies and procedures, early intervention, and loss mitigation requirements, … Read More
The CFPB published updated HMDA resource information including Technology Preview, Filing Instructions Guide for 2018 Data Collection and FAQs. It is reprinted below for convenience – Introduction For HMDA data collected in or after 2017, a web-based data submission and edit-check system (the HMDA Platform) is being created to process Home Mortgage Disclosure Act (HMDA) data. It is expected that … Read More
It’s that time again… Homeowners that the credit union has provided a Notice of Default to, and lived in their home when the foreclosure processes started, are eligible to participate in Washington State’s Foreclosure Fairness Act Mediation Program, unless the credit union has conducted less than 50 foreclosure sales during the previous year, and claimed their exemption status to the Department … Read More
