VIDEO: Closing a Loan on a Non-Business Day

VIDEO: Closing a Loan on a Non-Business Day

Adam Witmer
Regulation Z

Our Compliance Clips have returned! You may have noticed that we haven’t published a new Compliance Clip in the last few weeks. Well, that was due to some technical difficulties, Adam losing his voice, and taxes. Okay, maybe not all of those are fully to blame, but our Compliance Clips are back starting with this one. In this Compliance Clip (video), Adam answers a recent question he received regarding closing a loan on a day that is not considered a business day under the general definition of a business day in Regulation Z.

CFPB Issues Advisory Opinion on Digital Mortgage Comparison-Shopping Platforms

Adam Witmer
Regulatory Update, RESPA

On February 7, 2023, the CFPB issued an advisory opinion to protect Americans from double dealing on digital mortgage comparison-shopping platforms. According to the CFPB, companies operating these digital platforms appear to shoppers as if they provide objective lender comparisons, but may illegally refer people to only those lenders paying referral fees. The advisory opinion outlines how companies violate RESPA when they steer shoppers to lenders by using pay-to-play tactics rather than providing shoppers with comprehensive and objective information.

FDIC on the Changes to HMDA’s Loan Origination Threshold

Paula Parras
Regulatory Update, HMDA

On February 3, 2023, the FDIC issued a Financial Institution Letter to inform supervised institutions of recent changes regarding the Home Mortgage Disclosure Act (HMDA) reporting threshold for closed-end mortgage loans and the FDIC’s supervisory approach for enforcing related requirements. According to the FDIC, it does not intend to initiate enforcement actions or cite HMDA violations for certain failures to report closed-end mortgage data collected in the last three years.

NCUA Issues Letter Regarding Changes to HMDA’s Loan Origination Threshold

Adam Witmer
HMDA, Regulatory Update

On February 2, 2023, the NCUA issued a letter addressed to federally insured credit unions regarding the change to HMDA’s closed-end loan reporting threshold. According to the NCUA, the agency recognizes that credit unions affected by this change may need time to implement or adjust policies, procedures, systems, and operations to achieve compliance with these reporting requirements. Thus, the NCUA intends to take a flexible supervisory and enforcement approach similar to the approach being taken by the CFPB.

OCC Issues Bulletin Regarding Changes in HMDA Loan Origination Threshold

Adam Witmer
HMDA, Regulatory Update

On February 1, 2023, the OCC issued a bulletin to inform banks and OCC examining personnel that the loan origination threshold for reporting Home Mortgage Disclosure Act (HMDA) data on closed-end mortgage loans has changed. This is after a court decision was issued that the threshold for reporting is now 25 closed-end mortgage loans originated in each of the two preceding calendar years.

CFPB Proposes Rule to Control Credit Card Late Fees

Adam Witmer
Regulatory Update

On February 1, 2023, the CFPB issued a proposed rule to curb excessive credit card late fees that cost American families about $12 billion each year. According to the CFPB, major credit card issuers continue to profit off late fees that are protected by an expansive immunity provision. The Bureau believes that the proposed rule would help ensure that over the top late fee amounts are illegal. 

FRB Issues Notice Regarding the Changes to HMDA’s Loan Origination Threshold

Adam Witmer
HMDA

On January 31, 2023, the Federal Reserve Board issued a letter to institutions supervised by the Federal Reserve regarding the changes to home mortgage disclosure act (HMDA) loan volume reporting threshold for closed-end mortgage loans. The letter addresses the impact on financial institutions supervised by the Federal Reserve of recent changes as a result of litigation related to the HMDA reporting threshold for closed-end mortgage loans.

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