On July 6, 2012, President Obama signed into law the Moving Ahead for Progress in the 21st Century Act (Map-21) (H.R. 4348), which , includes the Biggert-Waters Flood Insurance Reform Act of 2012 (Biggert-Waters). Among numerous other provisions, Biggert-Waters re-authorizes the National Flood Insurance Program (NFIP) through 2017. The NFIP had been operating under stopgap extensions (18 since 2008) and shut down twice for several weeks. Just one of these lapses, in June 2010, stalled […]
Month: July 2012
OBSERVATIONS ON THE REGULATION Z PROPOSAL
“It’s only a proposal!” I can get carried away by big events like the 1,099 page proposal we got from the CFPB on Monday. The reminder that it is only a proposal helps keep me grounded It is also easy to get mad at the CFPB for the massive changes moving our way, but we got to remember that Congress is the big problem. Actually the CFPB is trying to take a few heroic actions […]
CFPB RELEASES COMBINED TIL/RESPA FORM PROPOSAL
Earlier today the Consumer Financial Protection Bureau (CFPB) published the first of three proposed revisions to Regulation Z that are expected this month. The 1,099 page release proposes model forms and new rules for mortgage loans. The proposal combines Truth in Lending and RESPA disclosures into a single document The comment period expires, for the most part, on November 6, 2012; however the comment period for rules on changes in the calculation of the finance […]
AMERICANS WITH DISABILITIES – EFFECTIVE COMMUNICATIONS
On May 31st the Department of Justice (DOJ) announced a comprehensive settlement agreement under the Americans with Disabilities Act (ADA) with Wells Fargo & Company to ensure equal access for individuals with disabilities to Wells Fargo’s services nationwide. Wells Fargo will pay up to $16 million to compensate individuals harmed by certain violations of Title III of the ADA. Title III of the ADA prohibits discrimination against individuals with disabilities by businesses that serve the […]
CFPB’s LATEST COMMENTS ON THE NEW COMBINED FORMS
Today the Consumer Financial Protection Bureau (CFPB) updated us on the extensive process used to develop the new combined TIL/RESPA forms. There is no question about it, the CFPB did exhaustive work designing the new combined forms. I expect the forms will be clearer and much easier to use. But there is one simple fact that Congress and the regulators refuse to grasp – borrowers do not read disclosures and they do not shop for […]