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The interpretive rule explains that because an heir has already acquired the title to the home, adding the heir as a borrower on the mortgage does not trigger the Ability-to-Repay requirements. The rule does not require the creditor to determine the heir’s ability to repay the mortgage before formally recognizing the heir as the borrower. As the named borrower, the heir may more easily be able to obtain account information, pay off the loan, or seek a loan modification.
The interpretive rule can also apply to other transfers, including transfers to living trusts, transfers during life from parents to children, transfers resulting from divorce or legal separation, and other family-related transfers.
CONFERENCE CALL: CHANGES TO REG Z
updated 05/23/16 03:02 PM
OT Rules, Deposit Recon. Practices
Credit union professionals can join a conference call briefing on May 25 by the Consumer Financial Protection Bureau (CFPB) regarding changes to Regulation Z implementing the Helping Expand Lending Practices in Rural Communities Act (HELP Rural Communities Act) contained in the Fixing America’s Surface Transportation Act (Public Law 114-94).
FINCEN PUBLISHES FINAL CDD RULES
updated 05/17/16 08:02 AM
TILA-RESPA Citations Resources
The Financial Crimes Enforcement Network (FinCEN) has issued final rules under the Bank Secrecy Act to clarify and strengthen customer due diligence requirements for banks and credit unions, brokers or dealers in securities, mutual funds, and futures commission merchants.