On November 30, 2016 the Consumer Financial Protection Bureau published an updated version of the Small Entity Compliance Guide entitled Real Estate Settlement Procedures Act (Regulation X) and Truth In Lending Act (Regulation Z) Mortgage Servicing Rules. The Guide is updated to reflect the August 2016 Final Rule that makes significant changes to the servicing rules contained in both regulations. The August 2016 Final Rule changes impact all financial institutions. The impact on small servicers […]
Category: CFPB
PHASE II OF THE HMDA REVISIONS
Implementing revised HMDA rules is a monumental task by any measure. The first phase is to determine scope and coverage, collect the data, and submit it to the CFPB. The second phase involves analyzing the data and determining the story told by that data. The scope of institutions covered by the revised rules has changed. The types of loans that are HMDA-reportable under the revised rules has changed. The list of information that must be […]
IMPACT OF THE ELECTION
Following this week’s election we all need to evaluate the impact on our lives, families, and our businesses. Change is definitely coming, but will not happen overnight. If you have a positive view of the future I hope your vision comes true. If you are fearful of the future I hope your fears are unfounded. We need to closely watch the actions of Congress and the White House over the next few years to judge […]
EFFECTIVE DATE FOR FINAL SERVICING RULES ESTABLISHED
On October 19, 2016 the final Servicing Rules published by the Consumer Financial Protection Bureau on August 6, 2016 were finally published in the Federal Register. The final rule clarifies, revises, or amends provisions regarding force-placed insurance notices, policies and procedures, early intervention, and loss mitigation requirements under Regulation X’s servicing provisions; and prompt crediting and periodic statement requirements under Regulation Z’s servicing provisions. The final rule also addresses proper compliance regarding certain servicing requirements […]
REGULATION B AND THE NEW UNIFORM RESIDENTIAL LOAN APPLICATION
On September 23 the Consumer Financial Protection Bureau (CFPB) published an Official Approval concerning the new Uniform Residential Loan Application and the collection of expanded Home Mortgage Disclosure Act information about ethnicity and race in 2017. The official approval was issued on September 23, 2016. Entities may rely on the official approval beginning January 1, 2017. The official approval is issued separately from, and without amending, the official interpretations to Regulation B contained in Supplement […]