Archive

CFPB Issues New RESPA FAQs

Recently the Consumer Financial Protection Bureau (CFPB) updated its Mortgage Servicing FAQs webpage to add 23 new FAQs that discuss selected topics relating to escrow accounts under Regulation X. The new FAQs provide a general overview of the escrow account provisions in Regulation X and address topics such as deficiencies, shortages, and surpluses.

WHAT’S GOING ON AT THE CFPB?

For the first four months of the Biden Administration the Consumer Financial Protection Bureau (CFPB), under the leadership of Acting Director David Uejio, set a blistering pace of proposed and final rules, recission of rules from the Trump Administration, and other actions. Since the beginning of May the agency has been quiet. The confirmation of Biden’s nominee for the Director, Rohit Chopra, has stalled. What is action is expected next? CFPB Leadership Mr. Chopra’s nomination […]

FIVE TRID FAQS ADDED

The Consumer Financial Protection Bureau has added five new questions and answers related to Housing Assistance Loans to the TILA-RESPA Integrated Disclosure FAQs. The new questions, which are effective immediately, cover: Are housing assistance loans covered by the TRID rule? What are the criteria for the Regulation Z Partial exemption from the Loan Estimate and Closing Disclosure Requirements? What are the criteria for the BUILD Act Partial Exemption from the Loan Estimate and Closing Disclosure […]

SPECULATION ENDS – FDCPA AND UDAP CROSS PATHS

Massive revisions to the Fair Debt Collection Practices Act (FDCPA), and its implementing Regulation F, have been unfolding over the past few years. The final rule is effective on November 30, 2021, although the CFPB has proposed to extend the effective date to January 29, 2022. Many banks want to operate under the assumption that the FDCPA and Regulation F do not apply to their operations. We have steadfastly maintained that the law and regulation […]

CFPB FINALIZES DELAY OF RECENT QM RULES

On April 27, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule extending the mandatory compliance date of the General Qualified Mortgage (QM) Final Rule from July 1, 2021 to October 1, 2022. Additionally, the April 2021 Final Rule affects the expiration of the Temporary GSE QM loan definition or “Patch.” Under the April 2021 Final Rule, the Temporary GSE QM loan definition will expire on October 1, 2022 or the date the […]