Newsroom

March 25, 2019

Compliance Blog answers questions on URLA, Reg Z

Compliance BlogIn two new Compliance Blog posts, NAFCU Vice President of Regulatory Compliance Brandy Bruyere and Regulatory Compliance Counsel Jennifer Aguilar answer questions related to the Federal Housing Finance Agency's (FHFA) new Uniform Residential Loan Application (URLA) and an exception to Regulation Z for business credit card accounts.

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In Friday's blog post, Bruyere explains that, although the 2004 version of the URLA – which is not compliant with the Home Mortgage Disclosure Act (HMDA) – is currently included in Regulation B's Appendix B model applications, the CFPB has indicated that use of the 2016 URLA is permissible.

However, the bureau has not indicated that the 2020 URLA is similarly in compliance with Regulation B.

Credit unions who sell loans to the GSEs will be required to use the new URLA for applications received on or after Feb. 1, 2020.

In today's blog post, Aguilar notes that many of the consumer regulations do not apply to business accounts. A section of Regulation Z says that "credit extended to a person for business purposes and credit extended to an entity are exempt from the regulation." However, there are a couple rules that apply to business accounts.

Aguilar then explains two provisions related to issuing cards and liability for unauthorized use for business credit cards.

Access these two Compliance Blog posts and more here.