Feb 13

Recent Compliance Issues: 1/10/14 – 1/23/14

  • Effective January 18, 2014, new appraisal rules kick in under Regulation B (Equal Credit Opportunity Act) requiring creditors to notify loan applicants of the availability, and automatically provide copies, of any appraisal done as part of the underwriting process.

    These include any internal valuation assessments or the results from on-line automated valuation models (AVM). Are your policies and procedures ready to provide required notices and appraisal copies in a timely manner?

    We can assist in making sure that you are ready for regulatory scrutiny in this area.

  • On Tuesday, January 14, 2014, Citizens Bank (Providence, RI) announced that it will start refinancing student loan debt via its Citizens Bank Education Loan program. Over recent history, there have been few options for refinancing outstanding student loan debt, possibly due to the availability of government guaranteed or subsidized loans.

    Regulatory requirements for student loans have been expanded in recent years in terms of both disclosures and servicing standards. Are you thinking about entering or re-entering the student lending market?

    Let us help you ensure that your disclosures, servicing standards, and written policies and procedures are ready for regulatory scrutiny