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
PROPOSED REGULATION B APPRAISAL RULE
Category: CFPB, Dodd-Frank Act, ECOA, Financial Reform, Lending Compliance, Regulation B
How refreshing to get a proposal from the CFPB that totals less than 100 pages. On August 15, 2012 the Consumer Financial Protection Bureau (CFPB) published a 58-page release that contains proposed rules to implement a Dodd-Frank Act requirement that amends appraisal rules to help inform mortgage applicants on how a creditor determines a property’s value prior to closing on the mortgage. It will also make it easier for loan applicants to determine if a loan
On August 10 the Consumer Financial Protection Bureau (CFPB) published two significant sets of proposed rules to revise the Truth in Lending (TILA) and the Real Estate Settlement Procedures (RESPA) Acts. Both rules deal with provisions related to the servicing of mortgage loans. TILA/Regulation Z – The proposed amendments implement the Dodd-Frank Act provisions regarding mortgage loan servicing. Specifically, the proposal implements addresses rules related to: Initial rate adjustment notices for adjustable-rate mortgages (ARMs); Periodic
DODD-FRANK CHANGES TO REGULATION O
Category: Dodd-Frank Act, Financial Reform, Lending Compliance, Regulation O
The Dodd-Frank Act contains over 2,000 pages of law. One page buried deep within the massive law has made two changes that impact Regulation O, the regulation that limits lending to insiders. The laws upon which Regulation O is based have been changed; the regulation itself has not been changed yet. The first change expands the definition of “extension of credit,” to include extending credit to a person and having credit exposure to the person
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