Lending

So much for the CFPB republishing Reg Z and not making any substantive changes. There are a couple things you should know about the CFPB’s version of Reg Z as it will require changes to your current credit card disclosures.

This is Part 2 of the ongoing “Are we completing our GFEs correctly?” series.

“Are we completing our Good Faith Estimates (GFEs) correctly?” This is how I started out my blog back on November 17th and if you read it, you discovered that most credit unions are not completing the GFEs correctly. As you can imagine, there are more common mistakes being made on the GFE than just those I described in my previous blog.

The holidays have definitely been a busy time for everyone. Buying presents and groceries and planning for holiday parties, it can really make things hectic. Showing no signs of slowing down during the holidays, the CFPB has recently released new prototype forms through the “Know Before You Owe” initiative. These forms represent the second release of forms that combine the HUD Settlement Statement and Truth-in-Lending disclosures to be given at consummation.

The Consumer Financial Protection Bureau unveiled a prototype credit card agreement yesterday (12/7) as part of the bureau’s Know Before You Owe campaign, which had previously released simplified model disclosures for mortgages and student loans.

Obviously a credit card agreement is fundamentally different than a model disclosure, so it will be interesting to see how this prototype evolves once feedback and testing is completed.

For more information about the new prototype, visit the CFPB website or this AP news story.

It’s easy to believe that your credit union does not discriminate in lending. However, you might want to spend some time making sure your belief is accurate given the current focus on fair lending by the NCUA’s Office of Consumer Protection, the Department of Justice and the CFPB.

Are we completing our Good Faith Estimates (GFEs) correctly?  This is a question that I frequently receive from credit unions even though we are almost two years removed from the required implementation of the new GFE.  And as it turns out, many credit unions are still not completing them correctly. So, with the anniversary approaching, I thought now would be a good time to review some common mistakes made on a very common form. As the title of today’s post indicates, this is the beginning of a series of posts describing common mistakes and instructions on how to complete the GFE correctly.

Today’s common mistake: “Your Adjusted Origination Charges”