The volume of changes from the Dodd-Frank Act that are currently unfolding is daunting. Based on the numerous complaints about the GFE and the HUD-1 I have fielded over the past 30 months, the issue of greatest concern may be the new integrated mortgage loan disclosures. The proposed rule for the Loan Estimate and Closing Disclosure covers 1,099 pages. Reading the proposal, gaining an understanding of the requirements, and trying your hand at completing the
DOES THE CFPB REALLY WANT COMMENTS FROM COMMUNITY BANKERS?
Category: CFPB, Dodd-Frank Act, Financial Reform, Uncategorized
The Consumer Financial Protection Bureau (CFPB) has cranked out more than 2,400 pages of new proposed regulations since July 9th. That is a lot to review in a short period of time. Let’s put this into context. The CFPB had two hours to draft each page starting from the date the Dodd-Frank Act became law. If you give the CFPB the benefit of the doubt and don’t start counting days until July 21, 2011, when
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On August 17, 2012 the Consumer Financial Protection Bureau (CFPB) released a 369-page proposal to amend Regulation Z. The amendments involve loan originator compensation. These proposals clarify and expand on existing regulations governing loan originator compensation and qualifications. They also implement new laws, including a restriction on the payment of upfront discount points, origination points, and fees on most mortgage loan transactions. Restriction on Upfront Points and/or Fees The proposed rule requires that, before a
INTERAGENCY PROPOSAL FOR APPRAISALS FOR HIGHER-RISK MORTGAGES
Category: CFPB, Dodd-Frank Act, Financial Reform, Lending Compliance, Regulation Z, Truth in Lending
On August 15, 2012 the Federal Reserve Board, the Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the Agencies) jointly proposed to amend Regulation Z, to implement a Dodd-Frank Act provision requiring appraisals for “higher-risk mortgages.” Comments are due on or before October 15, 2012. The 211-page proposed rule generally defines a “higher-risk mortgage” as a closed-end consumer
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