Loan Payment Cut-Off Times

Are you allowed to have a loan payment cut-off time for consumer-purpose, closed-end loans secured by a borrower’s primary dwelling?  The short answer is yes but there are a lot of “buts” to consider if you want to be compliant with Regulation Z.

Jerod explains more in the video.

Published
2021/07/20

Overdraft Changes Coming?

While there hasn’t been much change recently with respect to overdrafts, there are some things we need to keep an eye on.  First, the new Administration has a different take on consumer protection and what that means.  Thus, the CFPB is looking closer at current consumer protection laws and looking towards reform as we move forward.  We have no doubt that overdrafts will make their way back onto the CFPB’s rule-making agenda. 

Jerod explains more in the video.

Published
2021/07/20

Price Matching & Fair Lending

Fair Lending is a hot button issue!  Acting CFPB Director Uejio has stated, …fair lending enforcement is a top priority and will be emphasized accordingly.  But we will also look more broadly, beyond fair lending, to identify and root out unlawful conduct that disproportionately impacts communities of color and other vulnerable populations.  This is why it’s important to ensure your lenders understand the ins and outs of fair lending compliance. 

Jerod addresses a common question we get in the video.

Published
2021/07/19

Regulation E Provisional Credit

Regulation E is one area we consistently see a lot of errors.  Examiners are finding them too!  The error resolution process has a lot of timing requirements, liability calculations, etc. to wrap your brain around.  One of those is the provisional credit requirement.

Jerod explains more in the video.

Regulation E is just one of many regulatory requirements on the deposit side of your institution.  JOIN US for our webinar, “Deposit Operations Overview”, which will focus on the following:

  • Electronic Funds Transfer Act
  • Truth in Savings Act
  • Expedited Funds Availability Act
  • Fair Credit Reporting Act
  • Privacy
  • Overdraft Hot Spots
  • Unfair, Deceptive or Abusive Acts or Practices
  • Complaints & Much More!

TRID Loan Purpose & Construction Loans

TRID 2.0 construction loans: So, you’re doing a construction loan.  That means the loan purpose you disclose on the TRID disclosure is “construction”, right?  While that seems quite logical, it’s not always the case.  Even for what you consider to be a construction loan, you still have to work through the TRID loan purpose hierarchy.  You must first determine that it’s not a purchase and not a refinance before you get to construction.

Jerod says more about TRID Construction in the video.

Find TRID resources below!

Published
2021/07/19