On March 4, the Consumer Financial Protection Bureau (CFPB) released an Advanced Notice of Proposed Rulemaking (ANPR) to seek information from the public about certain issues related to Property Assessed Clean Energy (PACE) financing. In particular, the CFPB issued the ANPR to obtain more information (1) about the relationship between an assessment of a consumer’s “ability to repay” and the terms of a PACE financing agreement, and (2) related to the extension of Truth In Lending Act (TILA) general civil liability to PACE transactions.
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Revised Interagency Examination Procedures for Consumer Compliance
By Jeffrey M. Werthan on
Posted in Banking
As of May 1, the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council developed interagency examination procedures for:
- Truth in Lending Act (TILA), implemented by Regulation Z; and
- Real Estate Settlement Procedures Act (RESPA), implemented by Regulation X.
These procedures reflect Consumer Financial Protection Bureau amendments to Regulations Z and X published in the Federal Register in December 2013 and February 2015. Most of the changes to the procedures relate to the integrated mortgage disclosure requirements under TILA and RESPA, commonly referred to as the TRID requirements, which go into effect August 1 for all national banks and federal savings associations that offer consumer credit products covered by TILA and RESPA.
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