Recently the CFPB published the Fall 2015 version of its Semi-Annual Agenda. As expected, it is full of changes that will occupy us for years to come. Arbitration – The CFPB is in the early phases of the rulemaking process to address concerns related to the use of arbitration agreements in connection with credit cards, deposit accounts, payday loans and various other consumer financial products or services. The agency may prevent companies from using these agreements
Two innocent looking disclosures, but who knows the evil that lurks within. Loan Estimate: Liability after Foreclosure Taking this loan could end any state law protection you may currently have against liability for unpaid debt if your lender forecloses on your home. If you lose this protection, you may have to pay any debt remaining even after foreclosure. You may want to consult a lawyer for more information. Regulation: Section 1026.37(m)(7) requires the Loan Estimate
In remarks at the recent Mortgage Bankers Association Convention Consumer Financial Protection Bureau Director Richard Cordray conceded that the implementation process for CFPB’s new “Know Before You Owe” mortgage disclosure rule (aka as TRID) has not been as smooth as the agency would have hoped. But Cordray faulted vendors, not regulators. “Quite frankly, I have been disturbed by reports I have been hearing about the vendors on whom so many of you rely,” he said.
REVISED HMDA RULES PUBLISHED
Category: CFPB, HMDA, Regulation C
On October 15, 2015 the Consumer Financial Protection Bureau (CFPB) published revised Regulation C rules, which implement the Home Mortgage Disclosure Act. The revisions are effective for the most part on January 1, 2018, certain provisions are phased in through January 1, 2020. The revisions impact: Coverage – Coverage rules are slightly revised, but do not qualify as a major item on anyone’s list. The CFPB is playing this as meaningful reduction of regulatory burden.
Last week, the FDIC provided the industry with a Financial Institution Letter (FIL 43-2015) to detail what financial institutions can expect in terms of initial examinations after the October 3rd TRID implementation date. The first blog article in this series regarding TRID exam expectations can be found here. The Financial Institution Letter came after the CFPB released in mid-September the updated examination procedures the Bureau will rely on to complete initial exams. In July, Director
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