RHS Request for Comments Regarding Maximum Interest Rate for the Single Family Housing Guaranteed Loan Program (SFHGLP)

In Client and Friends Memos by BMG Memorandum

In the August 17, 2018, issue of the Federal Register (83 FR 41056, click here), the Rural Housing Service (RHS) published a request for information (RFI) seeking public comments on updating the provisions of the SFHGLP regarding the maximum interest rate, its impact on loan making to potential SFHGLP borrowers, and possible changes to the interest rate cap in order …

CFPB Request for Comments Regarding the CFPB’s Consumer Complaint Handling Processes

In Client and Friends Memos by BMG Memorandum

In the April 17, 2018, issue of the Federal Register (83 FR 16839, click here), the CFPB published a request for information (RFI) seeking comments and information to assist it in assessing its handling of consumer complaints and consumer inquiries and, consistent with law, considering whether changes to its processes would be appropriate.   The following is a redaction of …

CFPB Request for Comments on CFPB’s Guidance Materials and Activities

In Client and Friends Memos by BMG Memorandum

In the April 2, 2018, issue of the Federal Register (83 FR 13959, click here), the CFPB published a request for information (RFI) seeking comments and information to assist it in assessing the overall effectiveness and accessibility of its guidance materials, activities and implementation support; whether it would be appropriate to make changes, consistent with law, to the formats, processes, …

Real Estate Appraisal Threshold Increased for Commercial Real Estate Transactions

In Client and Friends Memos by BMG Memorandum

For financial institutions regulated by the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, or the Federal Deposit Insurance Corporation (collectively, the agencies), effective April 9, 2018, these agencies adopted a final rule amending their respective appraisal regulations requiring appraisals of real estate for certain transactions. The final rule adds a definition …

CFPB Request for Comments on the Substance of CFPB’s Inherited Regulations Implementing Federal Consumer Financial Laws

In Client and Friends Memos by BMG Memorandum

In the March 26, 2018, issue of the Federal Register (83 FR 12881, click here), the CFPB published a request for information (RFI) seeking comments and information to assist it in considering whether, consistent with its statutory authority to prescribe rules pursuant to the Federal consumer financial laws, it should amend the inherited regulations or exercise the rulemaking authorities that …

Home Equity Lending Interpretation Amendments Adopted by the Finance Commission of Texas and Texas Credit Union Commission

In Client and Friends Memos by BMG Memorandum

Effective March 29, 2018, the Finance Commission of Texas and the Texas Credit Union Commission (herein “Commissions”) adopted amendments to the following home equity lending Interpretations: §§153.1, 153.5, 153.14, 153.17, 153.84, and 153.86; adopted new §153.45; and adopted the repeal of §153.87.  These adopted changes to the Home Equity Lending Interpretations are published in the March 23, 2018, issue of …

CFPB Request for Comments on the Substance of CFPB’s Adopted Regulations Implementing Federal Consumer Financial Laws

In Client and Friends Memos by BMG Memorandum

In the March 21, 2018, issue of the Federal Register (83 FR 12286, click here), the CFPB published a request for information (RFI) seeking comments and information to assist it in considering whether, consistent with its statutory authority to prescribe rules pursuant to the Federal consumer financial laws, it should amend those rules it has promulgated since its creation or …