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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.
FINCEN ISSUES CDD FAQs
updated 07/25/16 10:52 AM
Plus, HMDA Resources Published
The Financial Crimes Enforcement Network (FinCEN) issued Frequently Asked Questions to help financial institutions, including credit unions, understand the scope of the new Customer Due Diligence (CDD) Requirements that were published in May. The CDD rules became effective on July 11, 2016 with compliance required by May 11, 2018.
CFPB PAYDAY LOANS WEBINAR
updated 07/18/16 02:40 PM
And, CUNA/League Compliance Tools
The Consumer Financial Protection Bureau (CFPB) is hosting a webinar on the recent Notice of Proposed Rulemaking on Payday, Vehicle Title, and Certain High-Cost Installment Loans on July 26.