Tag: ECOA

Consumer Financial Protection Bureau Announces Relief Options for Rescission Periods (Reg Z + TILA), TRID Rule Waiting Periods (TRID + Reg Z) and Delivery of Appraisals (ECOA Valuations Rule) – Dated April 29, 2020

Written by: Lloyd Rutherford, Staff Writer No matter how long you have been in the industry, the COVID-19 Pandemic is a first for all of us including the CFPB.  To offer consumers relief, the CFPB has added guidance to allow lenders some flexibility during this time.  All originators should read through these changes so that […]

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Compliance – Soft Pull vs. Hard Pull: Recently, our originators are requesting the ability to pull a soft pull on a client vs. a hard pull, as other lenders in the area are doing it, and it could be a cost-saving measure. Is this a regulatory issue?

Answer: QM/ATR only requires that the lender determine how they are going to validate credit history vs. telling you what type of report that you need. However, it will likely cause you regulatory issues under ECOA. When you issue adverse actions based solely on a soft pull, you do not have the entire picture of […]

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Facebook vs. HUD Show Down! NEW Social Media Ad Checklist!

Written By: Tammy Butler, Master CMB Social media marketing is growing, and as it does, Washington DC and the state AGs are taking note.  Facebook is in hot water with HUD over the filters companies or other licensed professionals can select when targeting their ads, because HUD believes these filters are a violation of the […]

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Has Fair Lending Been Neutered?

By: Tammy Butler, Master CMB Fair Lending Perspectives-The CFPB’s Latest Decision If you have anything to do with Fair Lending in your company, you have no doubt heard the news about the recent change at the CFPB with regard to Mulvaney’s decision to strip the Fair Lending Office of enforcement duties and move those duties […]

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