On February 27, 2023, the Consumer Financial Protection Bureau (CFPB) published a blog article regarding efforts by the Independent Community Bankers of America (ICBA) to gain approval for an application regarding consumer disclosures of a loan that provides either construction or construction-permanent financing In its April 28, 2022 application, the ICBA states it is not uncommon in rural communities for first-time homebuyers to build their first home because there are limited existing affordable “starter” homes. The […]
Category: CFPB
UPDATE ON APPRAISALS AND DISCRIMINATION
On February 14, 2023, the Federal Deposit Insurance Corporation, Consumer Financial Protection Bureau, U.S. Department of Housing and Urban Development, National Credit Union Administration, Federal Reserve Board, U.S. Department of Justice, Office of the Comptroller of the Currency, and the Federal Housing Finance Agency (the “agencies”) sent a joint letter to The Appraisal Foundation (TAF) expressing concerns with the Fourth Exposure Draft of Proposed Changes for the 2023 Edition of the Uniform Standards of Professional Appraisal Practice […]
TRID AND DAYLIGHT SAVING TIME
Daylight Saving Time (DT) begins on Sunday March 12, 2023 at 2:00 a.m. It ends on November 5, 2023 at 2:00 a.m. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in […]
TOWNSTONE MORTGAGE REVERSAL
During July 2020, the Consumer Financial Protection Bureau (CFPB) filed its first redlining complaint against a nonbank mortgage company, Townstone Mortgage (Townstone), under the Equal Credit Opportunity Act (ECOA) and Consumer Financial Protection Act (CFPA). The US District Court for the Northern District of Illinois recently granted Townstone’s motion to dismiss the CFPB’s complaint on the grounds that the ECOA applies to applicants and not to prospective applicants. The court ruled in favor of the […]
CFPB GUIDANCE ON DIGITAL COMPARISON-SHOPPING PLATFORMS
On February 7, 2023, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion to protect consumers from double dealing on digital mortgage comparison-shopping platforms. Companies operating these digital platforms appear to shoppers as if they provide objective lender comparisons, but may illegally refer people to only those lenders paying referral fees. When shoppers use a lender that is not the best option for their needs, they may end up with a lower quality lender […]