Articles by Michael McLain

New Rules for Open-End Lending

CUs can’t require any form of credit verification when members request advances, NCUA rules say.
Review policies and procedures to ensure conformance with NCUA’s updated guidance.
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‘Know Before You Owe’ Continues to Evolve

CFPB develops new ‘loan estimate’ and ‘closing disclosure’ forms.
CFPB’s “Know Before You Owe” project is an effort to combine the early disclosures required by TIL and RESPA into one document.
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Three Additional Rules From CFPB

Agency targets mortgage originations, escrow accounts, and high-cost loans.
The Consumer Financial Protection Bureau addresses mortgage originator standards, high-cost mortgages, and escrow accounts.
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CFPB Will Keep CUs Busy

Agency puts priority on consolidated mortgage disclosures.
Agency puts priority on consolidated mortgage disclosures.
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The Interaction of SCRA and Reg Z

SCRA’s interest-rate limitations trigger requirements under Truth in Lending and Reg Z.
The first thought a CU has when it learns a member is in the military or is about to go on active  duty is that it will have to comply with the Servicemembers Civil Relief Act.
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Court OKs Up-Front Card Fees

But fees are still limited during the first year following account opening.
The original rule regarding the limitation of fees during the first year after an account is opened remains in place and credit unions should continue to comply with it.
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Mortgage Ads On the Straight & Narrow

FTC’s final rule outlines what’s unfair or deceptive in advertisements.
In July, the Federal Trade Commission issued a final rule relating to unfair or deceptive acts and practices in mortgage loan advertisements.
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The 14-Day Question

Fed’s Reg Z final rules affect when CUs must send periodic statements.
Some CUs are confused about the 14-day timing requirement for periodic statements.
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Reg Z Rate Changes

Final rule addresses preferential rates, floor rates, and consumers’ ability to pay.
The Federal Reserve Board issued a Regulation Z final rule in March 2011 clarifying prior rules related to the Credit Card Accountability, Responsibility, and Disclosure Act.
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Reg Z Revisited, Again

Still more clarification is needed on the Fed’s Reg Z changes.
Still more clarification is needed on the Fed's Reg Z changes.
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