Recently the Federal Reserve Board (FRB) requested comment on a proposed rule under Regulation Z that requires creditors to determine a consumer’s ability to repay a mortgage before making the loan and also establishes minimum mortgage underwriting standards. We already have a similar requirement for Section 32 mortgages, Section 35 mortgages (higher-priced mortgage loans), and for open-end credit. The requirement is being expanded to all consumer mortgage loans (except home equity lines of credit, timeshare
New Regulation Z Dollar Threshold
Category: Dodd-Frank Act, Lending Compliance, Regulation Z, Truth in Lending
On March 24, 2011 the Federal Reserve Board approved a change to Regulation Z that increases the threshold for transactions exempt from Regulation Z from $25,000 to $50,000. This change was mandated by the Dodd Frank Act. The change is effective on July 21, 2011. So you may be wondering – What are the details of this change? What does the change mean to my bank? DETAILS Currently, the Truth in Lending Act (TILA) exempts
MOST RECENT RESPA ROUNDUP
Category: Lending Compliance, RESPA
The Department of Housing and Urban Development (HUD) recently published an issue of its periodic newsletter – RESPA ROUNDUP. This issue provides guidance on several issues related to the Good Faith Estimate (GFE) and the Uniform Settlement Statement (HUD-1). The articles include: * HUD-1 Line 803 Tolerance Violation; * Credit Report Charges; * Loan Originator Fails to Issue GFE; and * 4506-T 9Tax Transcript Fees. We must be totally crazy to write and read about
The one provision of the Dodd-Frank Act that strikes fear in the heart of bankers is the requirement to collect and report HMDA-like information on business loans. The provision is supposed to be effective on July 21, 2011. But since we don’t even have proposed regulations yet, we have suspected for some time now that the provision will be delayed. Leonard Kennedy, the recently appointed General Counsel of the Consumer Financial Protection Bureau, has made
Foreclosures are getting a lot of attention right now. In early February the news was that foreclosure-related documents were being signed and processed without being read. On April 13, 2011 the federal bank regulatory agencies took enforcement action against 14 financial institutions for engaging in a pattern of misconduct and negligence related to foreclosures. There are also rumblings of fair lending problems related to foreclosures. So why is the spotlight on foreclosures? It is a
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