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Regulation Z

MCUA Urges Changes to CFPB's TILA-RESPA Rule

Nov
15
MCUA Urges Changes to CFPB's TILA-RESPA Rule

On November 6, 2012, the Missouri Credit Union Association (MCUA) filed a comment letter with the Consumer Financial Protection Bureau (CFPB) on the agency’s proposed rule to amend Regulation Z, Truth in Lending Act (TILA), and Regulation X, the Real Estate Se

Posted By Sharon Bahr read more

Comments Filed on CFPB's Finance Charge Proposal

Nov
15
Comments Filed on CFPB's Finance Charge Proposal

On November 6, 2012, the Missouri Credit Union Association (MCUA) filed a comment letter with the Consumer Financial Protection Bureau (CFPB).

Posted By Sharon Bahr read more

Mortgage Loan Proposals Pending at Two Agencies

Oct
05

There are currently two pending proposals regarding appraisals for certain mortgage loans.  First, a Consumer Financial Protection Bureau (CFPB) proposal would amend Regulation B to implement changes to the Equal Credit Opportunity Act (ECOA) and require creditors to provide free copies of all written appraisals and valuations developed in connection with an application for a loan secured by a first lien on a dwelling.  Currently, federal credit unions are exempt from the appraisal delivery requirements of R

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CFPB Proposal to Amend Regulations X and Z

Sep
10
CFPB Proposal to Amend Regulations X and Z

Another comment letter was filed by the Missouri Credit Union Association (MCUA) and Credit Union National Association (CUNA) last week, this one with the CFPB in response to its proposed rule to amend Regulations X and Z to implement change

Posted By abucaida@mcua.org read more

Joint Agencies Propose Rule on Appraisal Requirements for "Higher-Risk" Mortgage Loans

Aug
20

On the same day as the Consumer Financial Protection Bureau (CFPB) proposed its own rule on appraisals and valuations discussed above, the joint federal banking regulators, including National Credit Union Administration (NCUA) and the CFPB, proposed a separate rule concerning the appraisal requirements relating to “higher-risk” mortgage loans.  General comments on this rule are also due on October 15, 2012, and this rule is also required to be finalized by the agencies by January 21, 2013. 

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NCUA Issues Legal Opinion Letter on MFL

Aug
20
NCUA Issues Legal Opinion Letter on MFL

National Credit Union Administration (NCUA) has issued a legal opinion letter (11-0620) again addressing multi-featured lending plans (MFL).  The letter reinforces earlier guidance from NCUA issued to federal credit unions in NCUA Letter (12-FCU-02, July 20, 2012). The legal opinion provides:

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"Finance Charge" Changes Under CFPB's RESPA/TILA Proposed Rule

Aug
06
"Finance Charge" Changes Under CFPB's RESPA/TILA Proposed Rule

As part of the Consumer Financial Protection Bureau’s (CFPB) 1099-page proposed RESPA/TILA rule, the CFPB is proposing some significant changes to Section 1026.4 of Regulation Z which defines the “finance charge.”  Importantly, these proposed changes will result in a more inclusive finance charge, which, absent further action by the CFPB, will increase the number of closed-end mortga

Posted By Sharon Bahr read more
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