The U.S. Department of Housing and Urban Development (HUD) recently announced that it has reached yet another agreement with a mortgage lender that apparently discriminated against a woman on maternity leave. The lender entered into the agreement to settle allegations that it denied woman a mortgage loan because she was pregnant and on maternity leave. The Fair Housing Act prohibits discrimination in the sale, rental, and financing of dwellings, and in other housing-related transactions, based on
On April 19th the Consumer Financial Protection Bureau (CFPB) proposed changes to the Qualified Mortgage (QM) and Servicing Rules. The proposal addresses five topics: Debt-to-Income Ratio Under the Ability to Repay rule, a lender may make a qualified mortgage (QM), a loan for which certain features are prohibited and fees that can be charged are limited. The rule provides for different types of QMs, the main type requiring that a consumer’s debt-to-income ratio (DTI) show
CFPB PUBLISHES REGULATION Z ESCROW GUIDANCE
Category: CFPB, Lending Compliance, Regulation Z, Truth in Lending
On April 19th the Consumer Financial Protection Bureau (CFPB) published TILA Escrow Rule Small Entity Compliance Guide. The 21- page Guide provides a summary of the TILA Escrow Rule. The guide also highlights issues that small creditors might find helpful to consider when implementing the rule. The Guide is available here.
REVISED HMDA GUIDE
Category: FFIEC, HMDA, Lending Compliance, Regulation C
On April 18th the Federal Financial Institutions Examination Council (FFIEC) published an updated version of A Guide to HMDA Reporting: Getting It Right. This is the first time the Guide has been updated since 2010. The 2013 edition reflects the transfer of authority over Regulation C from the Federal Reserve Board to the Consumer Financial Protection Bureau. Appendix D, comment 1003.2 is updated with the asset-size threshold exemption applicable to collection of 2013 data. There
PROPOSED REVISION TO 2013 FINAL ESCROW RULE
Category: CFPB, Dodd-Frank Act, Lending Compliance, Regulation Z, Truth in Lending
On April 11, 2013 the Consumer Financial Protection Bureau (CFPB) proposed revisions to the final rule it adopted in January 2013. The proposal clarifies the determination method for the “rural” and “underserved” designations and keeps in place certain existing protections for HPMLs until other similar provisions take effect in January 2014. The January rule can be read to cut off certain existing consumer protections before the new expanded protections take effect. The confusion arose because
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