The changes to Regulation Z are coming in waves. Combined, these waves may have the impact of a Tsunami.
The Federal Reserve Board has recently approved major new rules that amend the mortgage lending provisions contained in Regulation Z. The new rules are controversial. The changes are substantial. For the most part the new mortgage rules are effective on October 1, 2009.
More recently the Federal Reserve Board approved a major overhaul of the Regulation Z rules that govern open-end credit. The revised open-end credit rules are effective July 1, 2010.
Changes were also made by the Mortgage Disclosure Improvement Act, which is part of the Housing and Economic Recovery Act, and the Emergency Economic Stabilization Act of 2008. The Federal Reserve Board has published proposed rules to implement those laws. Those rules are effective July 30, 2009.
The many new rules will have a substantial impact on all lenders. This full-day seminar provides a comprehensive review of all of the new requirements. It explains the final rules and explains how the changes will impact your institution.
Upon completion of the program participants will understand the new rules. Among other items, the 1,200 pages of new rules:
Require an “early” Truth in Lending disclosure for a substantially broader category of loans;
Prohibit the imposition of fees prior to delivering the early TIL;
Delays closing after delivering the early TIL;
Require lenders to escrow for taxes and insurance on certain loans;
Create a new category of mortgage loans referred to as “higher priced mortgage loans,” which are loans secured by the consumer’s principal dwelling where the APR exceeds the average prime offer rate (APOR) by 1.5 or more percentage points in a first lien transaction or by 3.5 or more percentage points in a subordinate lien transaction;
Expand advertising rules for both open-end and closed-end credit;
Increase the compliance risk associated with making balloon loans that have a term of less than seven years; and
Completely revise, for open-end credit:
- The disclosures required for applications and solicitations;
- The account opening disclosure;
- The periodic statement; and
- The change in terms notices
The program is designed for financial institution
management, compliance officers, marketing officers, and others with risk management responsibilities for compliance in lending departments.
Jack Holzknecht is a principal with Pegasus Educational Services, LLC, a training firm headquartered in Louisville, Kentucky. He is an experienced consultant who has provided training to thousands of bankers and examiners for twenty-eight years. He has the ability to identify the key compliance issues from each regulation.
Jack’s career began in 1976 as a federal bank examiner. He later headed the form and software and education divisions of a regional consulting company. In that capacity he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by the Georgia, Iowa, Kentucky, Pennsylvania, Nebraska, New York and Texas bankers associations. He developed and delivered compliance training for the FDIC and OTS for ten years. He is a Certified Regulatory Compliance
Manager and a member of the National Speakers