2026 CBC Q4 Virtual Seminar

Main Subjects

01 Finance Charge and its Implications and Servicemember Issues

Although the credit and banking industry has changed dramatically, the Regulation Z rules governing finance charges have remained unchanged for more than 25 years. Due to the increasing number of new fees and charges identified during our loan file reviews, as well as many finance charge questions received through our hotline, we will explore this topic in depth.

As part of that discussion, we will look at the APR implications of finance charges and their impact on higher-priced mortgage loans (HPML), high-cost loans (HCL), qualified mortgages (QM), and other related compliance issues. We will also review examination procedures applicable to these loans. The QM discussion will include ability to repay (ATR), and points and fees, as both are a part of the QM process.

IMPORTANT NOTE: Before we begin our fourth quarter sessions, we will ask attendees to provide information about new fees that are appearing for all Regulation Z consumer loans - both real estate and non-real estate consumer loans. We will include a discussion of those fees in our presentation.

While many fees do not create compliance concerns, we will also discuss strategies for minimizing the impact of “newly” identified finance charge items, particularly in connection with mortgage loans.

02 Servicemember Issues

We have received numerous hotline questions regarding both the Servicemembers Civil Relief Act and the Military Lending Act. During this seminar, we will provide a detailed review of these laws and regulations, including the related examination procedures, to help ensure you understand your compliance responsibilities and the steps necessary to meet all applicable requirements. Exam procedures will be included in our discussion.