The Military Lending Act (MLA) has traditionally applied to three (3) types of loan products: payday loans, vehicle title loans, and refund anticipation loans. Under the Final Rule, beginning October 3, 2016, the MLA will apply to products generally covered by the Truth in Lending Act and Regulation Z, including deposit advance loans, installment loans, […]
The Department of Labor (“DOL”) has released its final rule that is intended to provide stronger overtime protection and clarity to both workers and employers. Read the Final Rule here. This general summary email is the first in a series our office will publish on the new overtime rule. To determine if a white collar […]
Back in October, 2015, the CFPB issued a Compliance Bulletin to remind participants in the mortgage industry of the prohibition on kickbacks and referral fees under the Real Estate Settlement Procedures Act (RESPA) and to describe the substantial risks posed by entering into Marketing Services Agreements (MSAs). The link to the Bulletin can be found […]
The CFPB has issued a final rule that revises the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA). The final rule is effective January 1, 2016. The CFPB created special small creditor provisions with regard to certain Regulation Z requirements. The revised definitions will affect the […]
On November 18, 2014, the CFPB issued a compliance bulletin regarding Social Security Disability Income Verification. The Bulletin was issued to remind creditors of their obligations under the Equal Credit Opportunity Act (ECOA) and Regulation B, with respect to consideration of public assistance income, and to highlight standards and guidelines regarding verification of Social Security […]
On September 25, 2014, the CFPB entered into a Consent Order with a Michigan title insurance agency to settle charges that the title agency entered into certain Marketing Services Agreements (“MSAs”) in violation of the Real Estate Settlement Procedures Act. This Consent Order provides three valuable takeaways for parties that have entered into MSAs with […]
Pennsylvania has enacted broad changes to the laws governing Powers of Attorneys (“POA”) for financial and property transactions. Below is a brief overview of some of the changes effective January 1, 2015. For POAs executed on or after January 1, 2015: A POA may be signed by another person on behalf of the principal only […]
Originally posted November 12, 2014 The CFPB has amended Regulation P, which requires, among other things, that financial institutions provide an annual disclosure of their privacy policies to their customers. So long as certain requirements are met, the amendment allows annual disclosures to be posted online, saving your Credit Union or CUSO time and money. […]
