Today the Consumer Financial Protection Bureau (CFPB) published the first part of a series of articles leading up to the publication of the combined Truth in Lending/RESPA disclosures. The first article looks at the origins of the Know Before You Owe project for simplifying mortgage disclosures. Tomorrow, the CFPB looks back at how the project unfolded. And then very soon, the CFPB will explain the long-awaited new proposed rule to make mortgage disclosures more effective […]
Category: Dodd-Frank Act
STATUS OF OTHER PENDING RULES
We received a lot of positive feedback about yesterday’s blog entry on the status of changes to Regulation Z. Several of you inquired about the status of other pending rules, particularly those involving Regulations B and C. Well here you go… Regulation B – The Dodd-Frank Act amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to report information concerning credit applications made by women- or minority-owned businesses and small businesses. The amendments […]
REGULATION Z – THE END OF THE WORLD AS WE KNOW IT
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 […]
REVISED INTERAGENCY FCRA EXAM PROCEDURES
On June 1, 2012 the Task Force on Consumer Compliance of the Federal Financial Institutions Examination Council released revised Interagency Examination Procedures for the Fair Credit Reporting Act. The revised examination procedures reflect recent amendments to the FCRA pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act). The Dodd-Frank Act revised sections 615(a) and 615(h) of the FCRA to require disclosure of credit scores and information relating to credit scores in: […]
DODD-FRANK ACT – STATISTICAL UPDATE
Information recently released by Davis Polk shows: As of June 1, 2012, a total of 221 Dodd-Frank rulemaking requirement deadlines have passed. This is 55.5% of the 398 total rulemaking requirements, and 78.9% of the 280 rulemaking requirements with specified deadlines. Of these 221 passed deadlines, 148 (67.0%) have been missed and 73 (33.0%) have been met with finalized rules. Regulators have not yet released proposals for 21 of the 148 missed rules. Of the […]