Thought Leadership
Is Calculation Validation Included in Your Compliance Program?
Posted on March 05, 2014
Is Calculation Validation Included in Your Compliance Program? Often we fall prey to not being able to see the forest because of the trees. The details overwhelm us and we miss the proverb...The APR: Semi-monthly Complications
Posted on December 31, 2013
The APR: Semi-monthly Complications There has been a marked increase over the past couple of years in credit plans being tailored to the payroll frequencies of respective borrowers and retail bu...Preparing for the 2014 HOEPA Regs
Posted on November 08, 2013
Preparing for the 2014 HOEPA Regs We've spent the last couple of months putting the finishing touches on revisions to the Carleton "HOEPA" module. Like any software update that deals with regul...Maximum Finance Charges... It's Not Just the Rate
Posted on August 29, 2013
Maximum Finance Charges... It's Not Just the Rate The regulatory climate is about as uncertain and volatile as I have seen it in my 28 plus years at Carleton. Of course, the big dog in the room...MOB Credit Insurance and the CFPB
Posted on July 17, 2013
MOB Credit Insurance and the CFPB It's been an active month for regulation, to say the least. A minor deluge of state based July 1st law changes mixed with the CFPB's upswing in both proposed a...Keeping the "Truth" in Truth-in-Lending
Posted on April 22, 2013
Keeping the "Truth" in Truth-in-Lending From the first introduction of a bill to promote "Truth in Lending" in 1960 by Senator Paul Douglas of Illinois to its adoption and enactment in 1969, the firs...MOB Credit Insurance Premiums: It's the Rounding
Posted on March 11, 2013
MOB Credit Insurance Premiums: It's the Rounding With the inception of the 2002 HOEPA revisions, we saw a dramatic increase in the use of outstanding balance (aka "monthly remittance") credit in...Contemplating the APR
Posted on February 12, 2013
Contemplating the APR 2013 has begun with a deluge of questions, issues, and investigative queries from a diverse cross-section of lenders in the consumer finance industry about the specifics of prop...Is It Really a 360 Day Year?
Posted on December 07, 2012
Is It Really a 360 Day Year? Whenever, in the discussion of consumer credit calculations, I hear someone say "Well, that's a 360 day year," I ask myself "Is it really?" and "Why would you want ...More on Truth in Lending APR Disclosures
Posted on October 12, 2012
More on Truth in Lending APR Disclosures It's pretty obvious that the subject of interest rates versus APR's just isn't going away. The topic arises daily in our customer service area with questions ...