Monthly Archives: November 2012

DELAYED REMITTANCE RULE

Posted on November 30, 2012 by Jack Holzknecht

On November 27, 2012 the Consumer Financial Protection Bureau (CFPB) announced that it is delaying the effective date of the final Regulation E Remittance Rules from February to May of 2013 to accommodate a few last minute changes. The CFPB … Continue reading →

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RAJ DATE RESIGNS

Posted on November 26, 2012 by Jack Holzknecht

Recently it was announced that Raj Date, the second highest ranking official at the Consumer Financial Protection Bureau (CFPB), plans to resign from the agency he helped create. Date is departing the CFPB on or around January 31, 2013 after … Continue reading →

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HAPPY THANKSGIVING!

Posted on November 22, 2012 by Jack Holzknecht

The Roman philosopher Seneca is credited with stating, “Nothing is more honorable than a grateful heart.” Since I always seek to be honorable, let me express my gratitude for all of you who have helped make this blog a success. … Continue reading →

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2013 THRESHOLDS

Posted on November 22, 2012 by Jack Holzknecht

On November 20, 2013 the Consumer Financial Protection Bureau published notices increasing several thresholds for 2013.  Two notices increased the dollar thresholds in Regulation Z (Truth in Lending) and Regulation M (Consumer Leasing) for exempt consumer credit and lease transactions. … Continue reading →

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INCREASED CIVIL MONETARY PENALTIES

Posted on November 20, 2012 by Jack Holzknecht

The Federal Civil Penalties Inflation Adjustment Act of 1990 (FCPIA Act)requires Federal agencies to adjust, by regulation, the Civil Monetary Penalties (CMPs) within their jurisdiction by a prescribed inflation adjustment at least once every four years. The Federal Reserve Board … Continue reading →

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EXTENDED DATE FOR NEW MORTGAGE DISCLOSURES

Posted on November 19, 2012 by Jack Holzknecht

On November 16, 2012 the Consumer Financial Protection Bureau (CFPB) announced that it will give creditors extra time to provide certain new disclosures required under the Dodd-Frank Wall Street Reform and Consumer Protection Act in order to allow a more … Continue reading →

Posted in CFPB, Dodd-Frank Act, Lending Compliance, Regulation X, Regulation Z, RESPA, Truth in Lending | Tagged , , , , , , | Leave a comment

HOW TO AVOID PROBLEMS RELATED TO UNEARNED DISCOUNT POINTS

Posted on November 8, 2012 by Jack Holzknecht

This is the final part of a five part series that explores issues related to discount points. The previous articles provided a primer on discount points, explored UDAAP concerns that result from unearned discount points, considered how unearned discount points … Continue reading →

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PROPOSED REVISONS TO REGULATION Z – DISCOUNT POINTS

Posted on November 7, 2012 by Jack Holzknecht

This is the fourth part of a five part series that explores issues related to discount points. The previous article considered how unearned discount points could result in fair lending violations. This part provides a glimpse of how changes to … Continue reading →

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HOW UNEARNED DISCOUNT POINTS MAY RESULT IN FAIR LENDING VIOLATIONS

Posted on November 5, 2012 by Jack Holzknecht

This is the third part of a five part series that explores issues related to discount points. The previous article explored UDAAP concerns resulting from unearned discount points. This article considers how unearned discount points may result in fair lending … Continue reading →

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HOW UNEARNED DISCOUNT POINTS MAY RESULT IN UDAAP VIOLATIONS

Posted on November 2, 2012 by Jack Holzknecht

This is the second part of a five-part series that explores issues related to discount points. The previous article provided a primer on discount points. This article explores UDAAP concerns that result from unearned discount points. Unearned discount points may … Continue reading →

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