On July 22, 2011 the CFPB published an interim final rule establishing Regulation D (§1004 of the Bureau of Consumer Financial Protection regulations) pursuant to the Alternative Mortgage Transaction Parity Act (AMTPA). The interim final rule is necessary to avoid a regulatory gap created by the amendments to AMTPA in the Dodd-Frank Act. Without an interim final rule that takes immediate effect, state housing creditors would no longer be able to make variable rate mortgage […]
Month: July 2011
SAFE ACT REMINDER
Every financial institution must assure that each Mortgage Loan Originator (MLO) is registered with the National Mortgage Licensing System (https://mortgage.nationwidelicensingsystem.org/fedreg/Pages/default.aspx) by July 29, 2011. For assistance in determining who is a MLO click for the free flowchart on Jackscomplianceresource.com.
HUD ISSUES ITS FINAL RESPA RULE
On July 11, just ten days before its rule-writing authority transfers to the new Consumer Financial Protection Bureau, HUD published revisions to Regulation X. The revisions generally address issues already covered in the Frequently Asked Questions and the RESPA Roundup. HUD did not touch any of the really screwed up issues that continue to plague lenders around the nation. The major revisions are summarized: The lender is not permitted to charge, as a condition for […]
SHUFFLING CHAIRS AT THE CFPB
It is being widely reported that President Obama will nominate former Ohio Attorney General Richard Cordray to head the Consumer Financial Protection Bureau (CFPB). The CFPB is scheduled to officially open for business on July 21, 2011. Cordray has been serving as the CFPB’s assistant director for enforcement during its formative period. Elizabeth Warren, who has been building the agency and was slated to be nominated as its permanent head, endorsed Cordray’s nomination. Expect the […]
New Dodd-Frank – Credit Score Disclosure Requirements
On July 6 the Federal Reserve Board approved final rules to implement the credit score disclosure requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. If a credit score is used in setting material terms of credit or in taking adverse action, the statute requires creditors to disclose credit scores and related information to consumers in notices under the Fair Credit Reporting Act (FCRA). The final rules amend: Regulation V (Fair Credit Reporting) […]