Recently the CFPB published its agenda as part of the Spring 2012 Unified Agenda of Federal Regulatory and Deregulatory Actions. The CFPB reasonably anticipates having the regulatory matters identified below under consideration during the period from June 1, 2012 to May 31, 2013. The next agenda will be published in fall 2012 and will update this agenda through October 1, 2013. Law/Regulation: Home Mortgage Disclosure Act/Regulation C Summary: The amendments made by the Dodd-Frank Act […]
Category: CFPB
MORE REGULATION Z (TIL) AND REGULATION X (RESPA)
The biggest big news on Monday July 9, 2013 was the 1,099 page proposal to combine TIL and RESPA forms. The other big news on Monday was the 293 page proposal to amend the Truth in Lending Act by expanding the types of mortgage loans that are subject to the protections of the Home Ownership and Equity Protection Act of 1994 (HOEPA), by revising and expanding the triggers for coverage under HOEPA, and by imposing […]
OBSERVATIONS ON THE REGULATION Z PROPOSAL
“It’s only a proposal!” I can get carried away by big events like the 1,099 page proposal we got from the CFPB on Monday. The reminder that it is only a proposal helps keep me grounded It is also easy to get mad at the CFPB for the massive changes moving our way, but we got to remember that Congress is the big problem. Actually the CFPB is trying to take a few heroic actions […]
CFPB RELEASES COMBINED TIL/RESPA FORM PROPOSAL
Earlier today the Consumer Financial Protection Bureau (CFPB) published the first of three proposed revisions to Regulation Z that are expected this month. The 1,099 page release proposes model forms and new rules for mortgage loans. The proposal combines Truth in Lending and RESPA disclosures into a single document The comment period expires, for the most part, on November 6, 2012; however the comment period for rules on changes in the calculation of the finance […]
CFPB’s LATEST COMMENTS ON THE NEW COMBINED FORMS
Today the Consumer Financial Protection Bureau (CFPB) updated us on the extensive process used to develop the new combined TIL/RESPA forms. There is no question about it, the CFPB did exhaustive work designing the new combined forms. I expect the forms will be clearer and much easier to use. But there is one simple fact that Congress and the regulators refuse to grasp – borrowers do not read disclosures and they do not shop for […]