On March 12, 2013 the Consumer Financial Protection Bureau (CFPB) announced the availability of a preliminary list of rural and underserved counties. The final list will be available before June 1, 2013. The list has significant impact on several regulatory requirements, as follows: On June 1, 2013, the CFPB’s Escrow Requirements under the Truth in Lending Act rule (Escrows Rule) will go into effect, which require certain creditors to create escrow accounts for a minimum of 5 […]
Category: CFPB
AVAILABILITY OF THE CHARM BOOKLET
Many bankers have relied on the Federal Reserve Board (FRB) for years as an inexpensive source for the disclosure booklets required for adjustable-rate mortgages. The booklet is frequently referred to as the Consumer Handbook for Adjustable-Rate Mortgages, or CHARM Booklet. Recently it came to my attention that the CHARM Booklet is no longer available through the FRB’s website since the underlying regulation, Regulation Z, has been transferred to the Consumer Financial Protection Bureau (CFPB). However, […]
APPEALS COURT DECISION CREATES TURMOIL
In the past few weeks the Consumer Financial Protection Bureau (CFPB) put in place over 3,500 pages of new regulations to implement various provisions of the Dodd-Frank Act. Or, maybe they didn’t. Yesterday the D.C. Circuit of the Federal Court of Appeals issued a ruling that the President can make recess appointments only when the Senate has formally adjourned between sessions of Congress. If the ruling stands, various appointments, including President Obama’s recess appointment of […]
FINAL LOAN ORIGINATOR COMPENSATION RULES NOW AVAILABLE
On Sunday January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z to revise and clarify existing regulations and commentary on loan originator compensation. The rules also implement Dodd-Frank Act provisions that prohibit certain arbitration agreements and the financing of certain credit insurance in connection with a mortgage loan. The 540-page final rule was published just hours before the Dodd-Frank mandated January 21, 2013 deadline. The rules take effect […]
CFPB PUBLISHES LOAN ORIGINATOR COMPENSATION RULES
On January 18, 2013 the Consumer Financial Protection Bureau (CFPB) announced publication of a final rule amending Regulation Z. The new rules revise and clarify existing regulations and commentary on loan originator compensation. The rules also implement Dodd-Frank Act provisions that prohibit certain arbitration agreements and the financing of certain credit insurance in connection with a mortgage loan. The rules take effect in January 2014, except that the prohibition on mandatory arbitration and on the […]