TRID’s Five-Year Assessment

TRID Training made easy with BCC

If you caught the October issue of Banking on BCC, it pointed out that we’ve been trying to meet the challenges of the TRID Rule for over five years now!  This also meant, it was time for the CFPB to assess the rule’s effectiveness and report back on what it found.  Those findings were recently released and will, at least in part, help the CFPB determine if any changes are warranted. 

While some evidence is “mixed”, findings were generally consistent that the TRIDRule improved consumers’ abilities to…understand their mortgages.  While the CFPB was unable to do a cost-benefit analysis, Director Kraninger acknowledged “sizeable implementation costs”, while stating that ongoing costs are less clear. 

Different groups and commenters chimed in on confusion surrounding the different definitions of “business day” that are used within the rule, as well as confusion over the 10% tolerance, liability after foreclosure, the Calculating Cash to Close table, as well as, other concerns.

Be sure to check out our November issue of Banking on BCC for more, including a look at some of the TRID violations noted by the CFPB.  Also, if you need TRID training, we have a lot of different webinar options so check out our store.

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2020-A Look Back & What Lies Ahead

If you’ve never joined us for our Forum, now is the time to check it out!  Our Forum is a FREE, one-hour webinar that we host four times a year.  We cover a variety of topics and allow you to pre-submit questions to ask our experts.

We have a Forum coming up later this month, that has quickly become a favorite!  It’s our “2020 – A Look Back & What Lies Ahead”.  We will look back at the regulatory news that has come down the pipe in the last 9-12 months.  Then, we will look ahead and talk about what’s on the horizon.  In a way, this Forum is kind of your checklist to make sure you haven’t missed anything big and that you don’t forget about things that you may need to prep your management for. 

We’d love to have you and your Team register today and join us on October 28th!


CFPB Continues Focus on FCRA Issues

In its latest edition of Supervisory Highlights, the CFPB indicated it’s seeing creditors pulling credit without a permissible purpose to do so.  The Fair Credit Reporting Act (FCRA) does not require consumers to consent prior to pulling credit (unless if for employment purposes), if you otherwise have a permissible purpose to do so.  For example, credit reports can be obtained …in connection with a credit transaction involving the consumer on whom the information is to be furnished and involving the extension of credit to, or review or collection of an account of, the consumer…

It’s also important to point out, that any contract you have with a consumer reporting agency likely requires you to …certify the purposes for which the information is sought, and certify that the information will be used for no other purposeWhile there are a variety of regulatory risks involved with reusing credit reports, you could be in violation of your contract if you reuse a previously obtained credit report, as well.

In addition to pulling credit without a permissible purpose, the CFPB indicated it’s also seeing issues in the handling of disputes and inaccurate reporting.  It’s clear the FCRA remains a focus of the CFPB, as evidenced by the Fall 2019 Supervisory Highlights, a special edition on Consumer Reporting. 

For more details on issues identified within the summer edition of The CFPB’s Supervisory Highlights, check out our October edition of Banking on BCC.

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CFPB’s Summer 2020 Supervisory Highlights

The CFPB recently released their Summer 2020 Supervisory Highlights which provides great insight into what examiners are seeing out in the field.  One of the areas addressed on the deposit side, paying a bonus under the Truth in Savings Act (Regulation DD), is one we haven’t seen in some time.

Regulation DD defines a bonus as, …a premium, gift, award, or other consideration worth more than $10 (whether in the form of cash, credit, merchandise, or any equivalent) given or offered to a consumer during a year in exchange for opening, maintaining, renewing, or increasing an account balance. The term does not include interest, other consideration worth $10 or less given during a year, the waiver or reduction of a fee, or the absorption of expenses.

As you are probably well aware, anytime you offer a bonus there are some additional disclosure requirements that need to be included in both your Truth in Savings account disclosure and any related advertising.  But, as the CFPB points out, your responsibilities don’t necessarily end there.

Examiners found that one or more financial institutions advertised bonuses for consumers who opened an account at the financial institutions and met certain requirements that the advertisement specified. These financial institutions failed to provide the promised bonuses in instances where consumers met the requirements.

The lack of quality control processes and failure to monitor the accounts to ensure consumers received the bonus they were due caused the CFPB to conclude that the advertisement of (the) bonus offer was misleading and inaccurate in violation of Regulation DD.  We’re guessing this could also show up in your consumer complaints as well.

This is a great reminder that if you offer a bonus in connection with a deposit account, ensure you’re doing what you say and saying what you do, both before and after the requirements are met.

This edition of the Supervisory Highlights also addressed Regulation E and a variety of lending topics, such as consumer reporting, fair lending and mortgage servicing to name a few.  We will also have a summary coming up in our October Magazine.

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Regulation E’s 60-Day Rule

What if a customer comes in and says, “these transactions are not mine” and when you look into it further, you find out it has been months or maybe even years since the suspected errors occurred?  Many financial institutions believe that consumers must notify you within 60 days of an error to get any of their money back but that’s one of the biggest myths related to the Regulation E error resolution requirements. 

Click on the video to listen to David explain more.

If you need more on Regulation E error resolution requirements, be sure to check out our webinar, “Regulation E: Errors & Disputes” which is available now OnDemand

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