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

Wisconsin

The Commissioner of Insurance issued a Bulletin on July 21, 2017 specifying the prima facie credit insurance rates effective for a three-year period starting January 1, 2018.

The new rates will be:

CREDIT LIFE INSURANCE

  • Single Decreasing Life - $ .40/$100/yr
  • Single Level Life - $ .74 /$100/yr
  • Joint Decreasing Life - $ .67/$100/yr
  • Joint Level Life - $1.24/$100/yr
  • Single Life M.O.B. - $ .616/$1000/mo
  • Joint Life M.O.B. - $1.029/$1000/mo

CREDIT ACCIDENT AND HEALTH INSURANCE – 12 Month Rate per $100 of initial insured indebtedness

  • 14 Day Retroactive - $.81
  • 14 Day Non-Retroactive - $.64
  • 30 Day Retroactive - $.60
  • 30 Day Non-Retroactive - $.60

 

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.