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

SBA Proposed Rule

The Small Business Administration is issuing a proposed rule amending several regulations relating to the 7(a) and 504 loan programs used by banks. The proposed changes are intended to streamline SBA processes and update or remove outdated provisions – for example, by replacing the Certified Lenders Program with SBA “delegated authority” criteria. The proposed changes include redefining cooperative businesses as … Read More

June Monthly Recap

June’s compliance recap, with a summary of regulatory issues that might impact the credit union, is available here.

Current Expected Credit Losses

On June 16, the Financial Accounting Standards Board (FASB) issued its final standard on credit losses; the Current Expected Credit Losses (CECL) model.  The standard follows a Life of Loan Concept that allows financial institutions to leverage its current internal credit risk systems as a framework for estimating expected credit losses.  The standard requires organizations to measure all expected credit … Read More

Payday Loan Rule – Part 4 of 3; Submitting Comments

Payday Loan Rule – Part 4 of 3, Submitting Comments The CFPB is accepting comments on its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans Rule, released June 2, 2016.  Comments on the proposed rule must be submitted by September 14, 2016. You may submit comments, identified by Docket No. CFPB-2016-0025 or RIN 3170–AA40, by any of the following … Read More

Proposed Payday Loan Rule – Part 3

The CFPB released its proposed Payday, Vehicle Title, and Certain High-Cost Installment Loans rule on June 2, in coordination with a field hearing on these small-dollar loans.  The 1333 page proposal aims to end payday debt traps, where borrowers seeking a short-term cash fix are saddled with loans they cannot afford and sink into long-term debt. Because of the scope … Read More

Consumer Compliance Outlook – Card Disputes

The latest issue of Consumer Compliance Outlook, published by the Federal Reserve, contains an informative article discussing when Regulation E and Regulation Z come into play in regards to consumers disputing transactions with merchants.  The article states Under Regulation Z, credit card issues have two separate legal obligations that could apply to merchant disputes.  In contrast, under Regulation E, debit … Read More