On August 15, 2012 the Federal Reserve Board, the Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller of the Currency (collectively, the Agencies) jointly proposed to amend Regulation Z, to implement a Dodd-Frank Act provision requiring appraisals for “higher-risk mortgages.” Comments are due on or before October 15, 2012. The 211-page proposed rule generally defines a “higher-risk mortgage” as a closed-end consumer […]
Category: CFPB
PROPOSED REGULATION B APPRAISAL RULE
How refreshing to get a proposal from the CFPB that totals less than 100 pages. On August 15, 2012 the Consumer Financial Protection Bureau (CFPB) published a 58-page release that contains proposed rules to implement a Dodd-Frank Act requirement that amends appraisal rules to help inform mortgage applicants on how a creditor determines a property’s value prior to closing on the mortgage. It will also make it easier for loan applicants to determine if a loan […]
CFPB – TWO MORE MAJOR PROPOSED RULES AMEND TIL AND RESPA
On August 10 the Consumer Financial Protection Bureau (CFPB) published two significant sets of proposed rules to revise the Truth in Lending (TILA) and the Real Estate Settlement Procedures (RESPA) Acts. Both rules deal with provisions related to the servicing of mortgage loans. TILA/Regulation Z – The proposed amendments implement the Dodd-Frank Act provisions regarding mortgage loan servicing. Specifically, the proposal implements addresses rules related to: Initial rate adjustment notices for adjustable-rate mortgages (ARMs); Periodic […]
HUGE UDAAP CASE
On Thursday July 19, 2012, the Office of the Comptroller of the Currency (OCC) and the Consumer Financial Protection Bureau (CFPB) each published releases announcing action against Capital One for Unfair, Deceptive and Abusive Acts or Practices (UDAAP) in violation of Section 5 of the Federal Trade Commission Act. This is the CFPBs first public enforcement action. The bank will pay $150 million in damages to 2.5 million affected consumers. This includes $140 million to […]
CFPB – SEMIANNUAL REGULATORY AGENDA
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 […]