Compliance Dates

2017/2018 Compliance Updates & Important Dates

November 2017

  • Annual renewal period begins for MLO registrations and updating bank information under SAFE Act on November 1, 2017.

December 2017

  • CFPB application process for determining counties as “rural” for Regulation Z qualified mortgage and higher-priced mortgage loan escrow rules will        terminate on December 4, 2017.
  • Temporary extension of foreclosure protection under the SCRA for service members expires December 31, 2017.
  • Annual renewal period closes for MLO registrations and updating bank information under SAFE Act on December 31, 2017.

January 2018

  • Adjusted Regulation Z thresholds and limits (CARD Act, ATR/QM and HOEPA) effective January 1, 2018.
  • Revised HMDA recordkeeping and reporting requirements effective January 1, 2018.
  • Lenders may begin using redesigned Uniform Residential Lending Application (URLA) form on January 1, 2018.
  • Lenders not using redesigned URLA must begin using Uniform Loan Application Dataset (ULAD) to supplement current URLA form beginning January 1, 2018.
  • Update HMDA-LAR with loans and applications that reached final disposition in fourth calendar quarter 2017 by January 31, 2018.
  • Update FHHLDS home loan activity format with fourth calendar quarter 2017 data by January 31, 2018 [non-HMDA reporting national banks receiving 50 or more home loan applications last year].

March 2018

  • 2017 HMDA LAR must be submitted to the CFPB/FRB by March 1, 2018.
  • 2017 CRA small business, small farm, and community development loan data must be submitted to applicable regulator by March 1, 2018 (except “small banks”).

April 2018

  • Prepaid card rules effective (except requirement to submit account agreements to CFPB) April 1, 2018.
  • CFPB changes to Regulation X and Regulation Z mortgage servicing rules regarding successors in interest and periodic statement for customers in bankruptcy effective April 19, 2018.
  • Update HMDA-LAR with loans and applications that reached final disposition in first calendar quarter 2018 by April 30, 2018.
  • Update FHHLDS home loan activity format with first calendar quarter 2018 data by April 30, 2018 [non-HMDA reporting national banks receiving 50 or more home loan applications last year].

May 2018

  • Compliance with FinCEN CDD rule regarding beneficial ownership mandatory May 11, 2018.

July 2018

  • Revised collection and return provisions of Regulation CC for electronic checks effective July 1, 2018.
  • Update HMDA-LAR with loans and applications that reached final disposition in second calendar quarter 2018 by July 31, 2018.
  • Update FHHLDS home loan activity format with second calendar quarter 2018 data by July 31, 2018 [non-HMDA reporting national banks receiving 50 or more home loan applications last year].

September 2018

  • (Previously exempt lenders that experience a change in status regarding their exemption from the flood insurance escrow requirements in 2018) Notices providing the option to escrow flood insurance must be distributed to customers of all outstanding designated loans by September 30, 2018 (previously exempt lenders that experience a change in status regarding their exemption from the flood insurance escrow requirements in 2018).

October 2018

  • Requirement to submit prepaid account agreements to the CFPB effective October 1, 2018
  • Compliance with July 2017 TRID amendments, guidance, clarifications, and technical corrections mandatory October 1, 2018.

November 2018

  • Annual renewal period begins for MLO registrations and updating bank information under SAFE Act on November 1, 2018.

December 2018

  • Annual renewal period closes for MLO registrations and updating bank information under SAFE Act on December 31, 2018.

 

*Compliance Dates provided by Young & Associates, Inc.  This calendar is designed to help you address current and upcoming requirements related to compliance with federal consumer protection and other select rules. The calendar is not intended as general advice on when to perform ongoing compliance management functions, but as a reminder of due dates for completing these tasks. And, as always, consult the particular law or regulation for details on coverage, etc.

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