As explained in the first part of this article implementing the new integrated disclosures is a massive task. Lenders that have a plan and get an early start on the process will complete the task by the August 1, 2015 deadline with minimal stress to all involved. We advocate a three-step process for implementing the New disclosures. Master the Material – Mastering 1,888 pages of regulation and related material doesn’t happen quickly. Most of us […]
Category: CFPB
IMPLEMENTING THE NEW INTEGRATED DISCLOSURES – Part I
The Consumer Financial Protection Bureau (CFPB) published final rules to implement the new integrated disclosures on November 20, 2013. The rules complete the Dodd-Frank mandate to combine the disclosures required by the Truth-in-Lending (TILA) and Real Estate Settlement Procedure Acts (RESPA). The regulations, the Official Interpretations and instructions for completing the forms are massive, covering 1,888 pages. Have you begun the implementation process yet? You have until August 1, 2015 to complete the task, […]
PROPOSED TIL CHANGES – GOOD NEWS?
On April 30 the Consumer Financial Protection Bureau (CFPB) proposed changes to Regulation Z rules related to the small servicer exemption and to the qualified mortgage rules. The proposal is on a fast track, with a 30-day comment period. Small Servicer The proposed changes to the small servicer rules are nice. The CFPB proposes an alternative small servicer definition for nonprofit entities that meet certain requirements, and amend the existing exemption from the ability-to-repay rule […]
WHERE’S HMDA HEADED? PART 5 – OPERATIONAL IMPROVEMENTS
The Consumer Financial Protection Bureau (CFPB) wants to improve the collection, reporting and sharing processes for Home Mortgage Disclosure Act (HMDA) data. This effort has the potential to reduce the burdens on lenders; but in its short history the CFPB has not earned a reputation for taking action solely in the interest of financial institutions. Collection and Reporting Approximately 70 percent of all loans eventually sold to a Government-Sponsored Enterprise use the Uniform Loan Delivery Dataset […]
HUGE UDAAP PENALTY
The CFPB announced that Bank of America has agreed to pay $772 million in refunds and penalties for deceptive credit card practices. Please don’t stop reading just because the case involves a big bank and credit card issues. The deceptive practices in this case involved debt cancellation and identity theft monitoring products which may be a concern for banks of any size and for many products other than credit cards. A simple rule for deciding […]