Some creditors never wanted to play the escrow game. Section 1026.35(b)(2(iii) of Regulation Z creates an exemption from escrowing on first-lien higher-priced mortgage loans for certain creditors. The exemption originally required action by June 30, 2013. Some creditors that were eligible for the exemption missed the June 30th deadline and the opportunity for the exemption. A subsequent revision to Regulation Z has reopened the window of opportunity for taking advantage of the exemption until January […]
Category: CFPB
KNOW BEFORE YOU OWE
What happened to the new integrated disclosure rules that were supposed to be published in September? Several months ago the Consumer Financial Protection Bureau (CFPB) announced that publication of the new rules would occur in October. Now the CFPB has announced a field hearing on Know Before You Owe: Mortgages on November 20, 2013 at 11:00 am EST. The meeting will be held in Boston. Past releases regarding the new integrated disclosures have referenced Know Before […]
AMENDMENTS TO REGULATION X AND Z SERVICING RULES
Recently the Consumer Financial Protection Bureau (CFPB) published an interim final rule that amends existing final servicing rules contained in Regulation X and Z. Comments will be accepted until November 22, 2013. The rule is effective January 10, 2014. The changes to changes routine is wearing thin, but these changes are helpful and do not significantly increase the compliance burden. Among other changes the amendments clarify the specific disclosures that must be provided before counseling […]
DILEMMA FOR ARMs WITH NO LOOK BACK PERIOD
Effective on January 10, 2014 Section 1026.20 of Regulation Z requires, when a rate change accompanied by a payment change occurs on an ARM, a notice to be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due. However a different timing rule (at least 25, but no more than 120, days before the first payment at the adjusted level is due) applies […]
EFFECTIVE DATE FOR NEW ARM NOTICES
Effective on January 10, 2014 § 1026.20 of Regulation Z requires that when a rate change accompanied by a payment change occurs on an ARM a notice must be sent to the consumer at least 60, but no more than 120, days before the first payment at the adjusted level is due (§ 1026.20(c)). An additional notice is required in connection with the initial interest rate adjustment provided to consumers. That notice must be provided at least […]