On June 2, 2021, the Consumer Financial Protection Bureau (CFPB) updated its Mortgage Servicing FAQs to include several questions and answers regarding the escrow account rules under the Real Estate Settlement Procedures Act, as implemented by Regulation X (12 CFR 1024). The escrow account Q&As include the following categories. General includes Q&As regarding: Definitions of…
read article →On June 30, 2021, FinCEN issued its list of priorities for anti-money laundering and countering the financing of terrorism (AML/CFT) (the Priorities) as required by the Anti-Money Laundering Act. The Priorities are intended to identify and describe the most significant AML/CFT threats facing the United States. The Priorities – listed, according to FinCEN, “[i]n no…
read article →On August 5, 2021, the CFPB issued an Interpretive Rule to provide guidance to only address certain Regulation Z timing requirements related to rescission of closed-end mortgages and the TILA-RESPA Integrated Disclosures (TRID) in light of recent legislation that designated Juneteenth as a Federal legal public holiday. In particular, the Interpretative Rule clarifies whether Saturday,…
read article →On June 23, 2021 (86 FR 32723), the Consumer Financial Protection Bureau (CFPB) issued an interpretative rule in which the CFPB asserts statutory authority to conduct examinations, at those institutions that it supervises, regarding the risks to active-duty servicemembers and their covered dependents that are presented by conduct that violates the Military Lending Act (MLA)….
read article →On March 31, 2021, the Consumer Financial Protection Bureau (CFPB) announced that Home Mortgage Disclosure Act (HMDA) Modified Loan Application Register (LAR) data for 2020 were published on the Federal Financial Institutions Examination Council’s HMDA Platform for approximately 4,400 HMDA filers. The published data contain loan-level information filed by financial institutions, modified to protect privacy….
read article →On May 10, 2021, the Federal Deposit Insurance Corporation (FDIC) proposed a rule to implement section 18(a)(4) of the Federal Deposit Insurance Act, which prohibits any person from making false or misleading representations about deposit insurance or from using the FDIC’s name or logo in a manner that would imply an uninsured financial product is…
read article →On May 14, 2021, the Consumer Financial Protection Bureau (CFPB) updated its TRID FAQs to include questions and answers regarding housing assistance loans under the Truth-in-Lending/Real Estate Settlement Procedures Act Integrated Disclosure Rule, as implemented by Regulation Z (12 CFR 1026). The Q&As discuss that housing assistance loans are generally subject to TRID but may…
read article →The Consumer Financial Protection Bureau (CFPB) published a Special Edition of Supervisory Highlights to share its observations in its prioritized assessment supervisory work conducted last year after the sudden onset of the COVID-19 pandemic. These assessments focused on assessing risks to consumers resulting from the pandemic. In May of 2020, the CPFB rescheduled about half of…
read article →Following the onset of the COVID-19 pandemic, the Consumer Financial Protection Bureau (CFPB) issued a number of policy statements to provide temporary flexibilities and guidance for financial institutions in consumer financial markets, including mortgages, credit cards, credit reporting and prepaid cards, on complying with their legal and regulatory obligations. Effective April 1, 2021, the CFPB…
read article →The NCUA remains committed to incorporating efficiencies into its examination and supervision program to address the effects of the COVID-19 pandemic on credit unions and their members. As the economic impact of the COVID-19 pandemic evolves, the NCUA will continue to provide the necessary guidance. Under its Letter to the Credit Unions, 21-CU-02 issued in January 2021,…
read article →The NCUA Board (Board) amended its share insurance regulation governing the requirements for a share account to be separately insured as a joint account by the National Credit Union Share Insurance Fund (NCUSIF) effective March 26, 2021. The final rule provides an alternative method to satisfy the membership card or account signature card requirement necessary for insurance…
read article →FinCEN recently updated its Frequently Asked Questions regarding the implementation of the Paycheck Protection Program (PPP), established by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act or the Act). The Small Business Administration (SBA) has issued FAQs regarding implementation of the PPP, some of which involve explaining the requirements under the Bank Secrecy…
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