Over the next six months Regulation Z will undergo the most extensive revisions in its 43 year history. The rules will primarily impact mortgage loan rules, for both open-end and closed-end credit. For mortgage loan disclosures, it will be the end of the world as we know it and the beginning of a brave new world of Regulation Z. Following is a summary of each piece of the revision process. Ability to Repay– A final […]
Category: CFPB
CFPB DELAYS ABILITY TO REPAY RULE
On May 31st the Consumer Financial Protection Bureau (CFPB) announced that it is seeking additional public comment on new data and information that it has received in a rulemaking to require lenders to revise Regulation Z to assess consumers’ ability to repay mortgage loans before extending them credit. The latest comment period will close on July 9, 2012. The CFPB is a new agency so we need to cut them a little slack. What the […]
CFPB IS REVIEWING PREPAID CARDS
On May 23, 2012, the Consumer Financial Protection Bureau (CFPB) took the first step toward adopting consumer protections for the fast-growing prepaid card market. The Bureau’s Advance Notice of Proposed Rulemaking seeks input on how to ensure that consumers’ funds on prepaid cards are safe and that card terms and fees are transparent. The Bureau’s rulemaking will focus on “General Purpose Reloadable” prepaid cards which allow consumers to load the cards with money upfront and […]
CFPB RULES WILL SIMPLIFY/STRANGLE MORTGAGE POINTS AND FEES
On May 9, 2012 the Consumer Financial Protection Bureau (CFPB) outlined rules it is considering that would simplify (or strangle) mortgage points and fees. These rules, which the CFPB expects to propose this summer and finalize by January 2013, would make it easier for consumers to understand mortgage costs and compare loans so they can choose the best deal. The CFPB is considering proposals, required by the Dodd-Frank Wall Street Reform and Consumer Protection Act […]
MANAGING SERVICE PROVIDER RISKS
On April 13th the Consumer Financial Protection Bureau (CFPB) released a bulletin clarifying that financial institutions may be held responsible for the actions of the companies with which they contract. The other federal bank regulatory agencies have held the same position for years. Banks and nonbanks contract with service providers for a number of reasons. They may use service providers to develop and market additional products or services or to provide expertise. Banks may also […]