Compliance Alerts

Compliance Alert

Colorado - 7/22/2017

The following information is presented by the Carleton Research Department. In order to keep our customers abreast of what is happening in the consumer credit and credit insurance industries, the following law changes have been compiled for your review.  Please check to see if any of the listed changes will impact your operations.

*This alert is intended to convey general information only and not to provide legal advice or opinions.
 

State Law Changes

Colorado

Colorado UCCC Administrator Julie Ann Meade issued an official opinion on August 7, 2017 declaring that debt cancellation/debt suspension agreements other than GAP coverage are considered a state finance charge under the Colorado Uniform Consumer Credit Code.

The Opinion declares that debt cancellation/debt suspension agreements are not permissible “additional charges” under the Code.  Previously, the Administrator specifically addressed GAP (Rule 8), IUI Premiums (Rule 4), and Single Premium Non-Credit Insurance (Rule 3) by rule.

Affected organizations will have 120 days from the date of the Opinion to comply.

 

TRUTH IN LENDING ANNUAL THRESHOLD ADJUSTMENTS
Effective January 1, 2018

The following information is presented by the Carleton Research Department. In order to keep our customers abreast of what is happening in the consumer credit and credit insurance industries, the following law changes have been compiled for your review.  Please check to see if any of the listed changes will impact your operations.

*This alert is intended to convey general information only and not to provide legal advice or opinions.
 

HOEPA
Sec. 1026.32(a)(1)(ii)           $21,032 – points and fees coverage test
Sec. 1026.32(a)(1)(ii)(B)     $  1,052 -  points and fees dollar trigger

ATR/QM
Sec. 1026.43(e)(3) – Qualified Mortgage Status

  • A. For a loan amount greater than or equal to $105,158: 3 percent of the total loan amount;
  • B. For a loan amount greater than or equal to $63,095 but less than $105,158: $3,155;
  • C. For a loan amount greater than or equal to $21,032 but less than $63,095: 5 percent of the total loan amount;
  • D. For a loan amount greater than or equal to $13,145 but less than $21,032; $1,052;
  • E. For a loan amount less than $13,145: 8 percent of the total loan amount.