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On January 18, 2015 the Consumer Financial Protection Bureau (CFPB) approved final changes to Regulations X and Z. The changes are effective on August 1, 2015. The final rule: Extends the timing requirement for revised disclosures when consumers lock a rate or extend a rate lock after the Loan Estimate is provided; Clarifies placement of the Nationwide Mortgage Licensing System and Registry ID (NMLSR ID) on the integrated disclosures; Permits certain language related to construction […]

The Department of Housing and Urban Development (HUD) released an updated Servicemembers Civil Relief Act (SCRA) Notice, form HUD-92070, in late December 2014 to replace the SCRA Notice which expired on November 30, 2014. The updated SCRA Notice issued in December included information contradictory to the timeframe of protections afforded to servicemembers in the SCRA, as amended. The SCRA Notice, form HUD-92070, provides information on the following: 1) legal rights and protections under SCRA; 2) […]

A number of different federal lending compliance regulations use the term “manufactured home.” For example, the appraisal rules in Section 1026.35(c) of Regulation Z contain exemptions for both mobile home and manufactured homes, but the exemptions differ for one category of home versus the other. For HMDA and Regulation C lenders must gather and submit information regarding, among other categories, the property type. There seems to be much confusion regarding the definition of “manufactured home.” […]

The Consumer Financial Protection Bureau (CFPB) recently published a blog article reporting the results of their National Survey of Mortgage Borrowers. Key findings from the survey include: Almost half of consumers who take out a mortgage for home purchase fail to shop prior to application; that is, they seriously consider only a single lender or mortgage broker before choosing where to apply. The tendency to shop is somewhat higher among first-time homebuyers. The primary source […]

Numerous regulatory requirements have thresholds that change annually. Following is a review of several of the lending thresholds that have changed recently. CRA – Small Bank and Intermediate Small Bank – Effective January 1, 2105 each federal financial institution regulatory agency defines the term “small bank” to mean a bank that, as of December 31 of either of the prior two calendar years, had assets of less than $1.221 billion. The term “intermediate small bank” means a small […]