HMDA – HOEPA STATUS
Category: CFPB, Dodd-Frank Act, Financial Reform, HMDA, Lending Compliance, Regulation C, Regulation Z, Truth in Lending
Section 1003.4(a)(13) of Regulation C requires that the Loan Application Register indicate, among other items, whether the loan is subject to the Home Ownership and Equity Protection Act of 1994 (HOEPA), as implemented in Regulation Z (12 CFR 1026.32). Under current rules a loan secured by a consumer’s principal dwelling is subject to HOEPA if the loan has a high rate or high fees. Currently a loan has high fees if the total points and
It appears that the Consumer Financial Protection Bureau (CFPB) will be busy during 2014, but a lot less busy than 2013. On December 3, 2014 the CFPB published a semi-annual update to its rulemaking agenda. The fall 2013 agenda reflects both continuing work on rulemakings mandated by the Dodd-Frank Act and significant issues in other markets for consumer financial products and services. In the past year the CFPB issued rules to implement Dodd-Frank Act requirements
On December 12, 2013 the Federal Reserve Board, The Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the National Credit Union Administration, and the Office of the Comptroller of the Currency jointly published a final rule that creates exemptions from certain appraisal requirements for a subset of higher-priced mortgage loans. The exemptions are intended to save borrowers time and money while still ensuring that the loans are financially sound.
On December 11, 2013 the Department of Housing and Urban Development (HUD) published a final rule to establish a definition of “qualified mortgage” (QM) for the single family residential loans that HUD insures, guarantees, or administers that aligns with the statutory ability-to-repay criteria of the Truth-in-Lending Act (TILA) and the regulatory criteria of the definition of QM promulgated by the Consumer Financial Protection Bureau (CFPB). The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank
NEW INTEGRATED DISCLOSURES RELEASED
Category: CFPB, Dodd-Frank Act, Lending Compliance, Regulation X, Regulation Z, RESPA, Truth in Lending
On October 20, 2013 the Consumer Financial Protection Bureau published the new rules for the integrated disclosures. The new rule is 1,888 pages long and is effective on August 1, 2015. The CFPB is not revising finance charge rules at this time. A copy of the new rule is available here.
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