Blog

The January 2015 issue of the FFIEC’s CRA/HMDA Reporter has several good reminders about HMDA issues. The lead article, HOEPA Changes and New Edit Changes, focuses on changes to Regulation Z (HOEPA) rules that were effective in January 2014 and impacted the 2014 HMDA data just submitted by your bank. The changes lowered the rate spread threshold of HOEPA eligible loans, and expanded coverage to certain home purchase mortgage products. The Reporter is available by

As we originally reported in Spring 2014 the Supreme Court of the United States (SCOTUS) granted review in the case of Jesinoski v. Countrywide Home Loans. In the case, argued on November 4, 2014, and decided January 13, 2015, SCOTUS reversed and remanded the decision of the Eighth Circuit Court of Appeals. In a unanimous opinion delivered by Justice Scalia, the court held that a “borrower exercising his right to rescind under the Act need only provide written

On January 29, 2015 the Consumer Financial Protection Bureau (CFPB) proposed several changes to Regulation Z that impact small creditors, particularly in rural and underserved areas. The proposal would increase the number of financial institutions able to offer certain types of Qualified Mortgages (QM) in rural and underserved areas. Ability -to-Repay rules, which took effect in January 2014, require lenders to make a reasonable and good-faith determination that prospective borrowers have the ability to repay

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)